- 17 - petitioners contend that, because (according to petitioners) B&W did not receive barter income from Kelso, they are not negligent for their failure to report that income. In deciding whether Badell and Wilson were negligent, we consider their legal education and their years of legal experience. See Tippin v. Commissioner, 104 T.C. 518, 534 (1995); Glenn v. Commissioner, T.C. Memo. 1995-399, affd. 103 F.3d 129 (6th Cir. 1996). Petitioners have not shown that they acted with reasonable cause and in good faith with respect to these issues. They did not explain how they prepared their individual returns for 1994, 1995, and 1996, or provide any authority for the positions they took on those returns. We conclude that petitioners are liable for the accuracy-related penalty for negligence for 1994, 1995, and 1996. Decisions will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
Last modified: May 25, 2011