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All of the expenses of the mobile unit are to be treated
either as ordinary or as capital expenses of petitioners’ timber
farm.
Additions To Tax
For 1987 and 1988, respondent asserts against petitioners
the negligence and substantial understatement additions to tax
under sections 6653(a) and 6661, respectively. For 1989,
respondent asserts against petitioners the accuracy-related
penalty under section 6662(a).
Respondent emphasizes petitioners’ burden of proof as to
the above additions to tax and penalty, and as evidence of
petitioners’ negligence, respondent points to many errors on
petitioners’ Federal income tax returns.
We do not believe, however, that the additions to tax and
penalty asserted by respondent against petitioners in this case
are appropriate. Many of the errors on petitioners’ tax returns
are attributable to the amateurish books and records that
petitioners unfortunately established to keep track of their
many business, investment, and personal activities. In our
opinion, the origin and maintenance of these books and records
are traced to petitioner’s overconfidence that he is a man of
many talents -- even bookkeeping and accounting.
Despite his zeal to do everything himself, petitioner hired
an accounting firm to prepare petitioners’ income tax returns.
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