Patrick C. Badell and Lillian A. Badell - Page 17




                                       - 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