- 9 - 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.Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011