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We also note that petitioners were careless by not retaining
sufficient records to establish 20 The Point as their principal
residence. On the basis of the record as a whole, we also
conclude that petitioners have not carried their burden of
proving that they acted with reasonable cause. Therefore, we
hold that they are liable for the accuracy-related penalty for
negligence under section 6662(a).
To reflect the foregoing,
Decision will be entered
under Rule 155.
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