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necessary expenses of a trade or business during the years in
issue.
In light of the above, we find it unnecessary to explore
whether or not petitioner's home building activity was entered
into for profit. We note, however, that there is a strong
suggestion that petitioner's primary motivation seems to have
been the building of a house for his mother rather than making a
profit.
Respondent also determined that petitioners are liable for
accuracy-related penalties under section 6662(a) for 1995 and
1996 for negligence. Section 6662(a) provides that "there shall
be added to the tax an amount equal to 20 percent of the portion
of the underpayment to which this section applies." Section 6662
applies to "the portion of any underpayment which is attributable
to", inter alia, negligence or disregard of rules or regulations.
Sec. 6662(b)(1). Negligence "includes any failure to make a
reasonable attempt to comply with the provisions of * * * [the
Internal Revenue Code], and the term 'disregard' includes any
careless, reckless, or intentional disregard." Sec. 6662(c).
Petitioners argue that they employed a qualified tax return
preparer and any errors were due to the return preparer. In some
circumstances reliance upon a qualified return preparer may
alleviate a taxpayer's liability for penalties. See Ewing v.
Commissioner, 91 T.C. 396, 423-424 (1988), affd. without
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