Jerry L. Crabtree - Page 41

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                  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                   
                  To reflect the foregoing and concessions by the                     

                                             Decisions will be entered                
                                        under Rule 155.                               

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