-16-
that their income tax returns contain "so many mistakes" that she
did not want them admitted into evidence. Her casual approach to
tax return preparation is illustrated by her testimony concerning
the Cirtex corporate returns: "There's a lot of hiding figure, or
hiding fact elicited in this return. * * * we have to file, so we
file something."
Based on the record before us, we conclude that petitioners
were negligent and disregarded rules or regulations in preparing
their 1989 return. Accordingly, petitioners are liable for the
accuracy-related penalty on the entire underpayment for 1989.
To reflect concessions by respondent, as well as the
foregoing,
Decision will be entered
under Rule 155.
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