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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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