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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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Last modified: May 25, 2011