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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.
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