Terry Duane Beall and Joyce Engel Beall - Page 26

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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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