- 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.Page: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41
Last modified: May 25, 2011