- 10 - taxpayer acted in good faith with respect to such portion. Sec. 6664(c). On the basis of this record, we conclude that petitioners are liable for accuracy-related penalties under section 6662(a). Petitioners claimed deductions to which they were not entitled. Petitioners also failed to provide any reasonable explanation or any credible evidence to substantiate their entitlement to the deductions. In this regard, we find that petitioners' actions were not those of a reasonable and prudent person under the circumstances. Accordingly, petitioners are liable for accuracy- related penalties under section 6662(a) for 1993 and 1994. Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011