- 41 -
Petitioners contend that they maintained adequate and
accurate accounting records. Petitioners assert that
Crabtree Investments did not intentionally or unintention-
ally understate its income from sales during the audit
period. They also argue that “any understatement of tax as
a result of the adjustments made at trial is insubstantial
and not due to any negligence or intentional disregard of
rules or regulations.” On the basis of the entire record
of these cases, we find that petitioners have not met their
burden of proving that the underpayment of tax is not
attributable to negligence or disregard of rules or
regulations. Accordingly, we hereby sustain respondent’s
determination that petitioners are liable for the accuracy-
related penalty under section 6662(a) for the years in
issue.
To reflect the foregoing and concessions by the
parties,
Decisions will be entered
under Rule 155.
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