Clair and Judith Worthington - Page 6




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          Taxpayers are required to keep such books or records "at all                
          times available for inspection by authorized internal revenue               
          officers or employees, and [these records] shall be retained so             
          long as the contents thereof may become material in the                     
          administration of any internal revenue law."  Sec. 1.6001-1(e),             
          Income Tax Regs.  When they destroyed the worksheets used in the            
          preparation of their income tax returns, and failed otherwise to            
          maintain adequate books and records, petitioners did not exercise           
          due care and failed to do what a reasonable and ordinarily                  
          prudent person would do.  Accordingly, we hold that petitioners             
          were negligent with respect to the entire underpayment for each             
          of the years 1994 and 1995 and, therefore, are liable for the               
          accuracy-related penalties under section 6662(a).                           
               To reflect the foregoing concessions,                                  


                                                  Decision will be entered            
                                             under Rule 155.                          


















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