Robert E. and Carloyn S. Holmes - Page 43

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             bear the burden of proving that respondent's determination               
             of negligence is incorrect.  See Neely v. Commissioner,                  
             supra at 947-948; Bixby v. Commissioner, 58 T.C. 757, 791                
             (1972).                                                                  
                  Petitioners maintain that they provided all relevant                
             information to their accountant and acted reasonably and                 
             in good faith in relying on his tax advice and tax return                
             preparation.  Although petitioners acknowledge that they                 
             erroneously deducted two personal expenses as farming                    
             expenses in 1987 and one in 1988, petitioners characterize               
             these errors as a "mistakes".                                            
                  Petitioners have not satisfied their burden of proving              
             that respondent's imposition of the additions to tax for                 
             negligence is erroneous.  Petitioners commingled funds for               
             all of their business activities in a single bank account                
             and did not maintain complete or accurate records of the                 
             activities relating to that account.  Petitioners also                   
             failed to retain receipts or invoices to support their                   
             ledger entries.  See sec. 6001.  Petitioners also recorded               
             several personal expenses on the books maintained for                    
             farming expenditures, and periodically paid farm expenses                
             from their personal checking accounts.  Petitioners' record              








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