- 26 - 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.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26
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