- 19 - In determining whether petitioners were negligent in the preparation of their returns, we take into account petitioner Mr. Dodge's legal and tax experience. Mr. Dodge prepared 75-100 farm tax returns a year. Attorneys who specialize in taxation are held to a higher standard of care. Tippin v. Commissioner, 104 T.C. 518, 534 (1995). Additionally, the size of the tax losses claimed by petitioners in relation to the revenue earned from the horse-breeding activity, combined with the substantial enjoyment that petitioners derived from the activity, created a situation that was "too good to be true" within the meaning of section 1.6662-3(b)(1)(ii), Income Tax Regs. Accordingly, petitioners are liable for the section 6662(a) penalties. To reflect the foregoing, Decision will be entered under Rule 155. 4(...continued) substantial. As a result of our decision with respect to the negligence penalty, we need not address this issue.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19
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