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businesses. Accordingly, we hold that petitioners are not
entitled to deduct the expenses as ordinary and necessary
business expenses.
II. Accuracy-Related Penalty for Negligence
Section 6662(a) imposes a penalty in an amount equal to 20
percent of the portion of any underpayment to which the section
applies. The section applies to, among other items, the portion
of an underpayment attributable to negligence or disregard of the
rules or regulations. Sec. 6662(b)(1). Petitioners did not at
trial or in their brief dispute their liability for the accuracy-
related penalty for negligence. As a result, petitioners have
failed to carry their burden of proof and are liable for the
penalty.
We have considered the other arguments made by the parties
and found them to be either irrelevant or without merit.
To reflect concessions by the parties,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011