Preston L. and Ruby M. Payton - Page 10

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          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.                          





















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