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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.
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