- 19 - Petitioners have failed to show that they were not negligent and did not disregard rules and regulations. Petitioners claimed deductions to which they were not entitled. They failed to show that they maintained adequate books and records to provide a rational basis for their claimed deductions and losses. They claimed depreciation allowances for property for periods when the property was held by other entities. They claimed other business deductions for which they have produced no substantiation. Accordingly, we sustain respondent’s determination on this issue. Petitioners argue that the various personal misfortunes and business pressures previously described “limited and restricted * * * [petitioner’s] access to information, and records necessary to complete his returns.” The sparse evidentiary record regarding these various misfortunes does not establish, however, that any such adverse circumstances would have persisted in 1991 and 1992, when petitioners’ returns were finally filed with the assistance of a certified public accountant. Moreover, we are unconvinced that the underpayments as determined herein are attributable to petitioners’ lack of information and records rather than to petitioners’ lack of good faith in attempting to comply with the provisions of the Internal Revenue Code. Accordingly, we sustain respondent’s determinations on these issues.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011