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required to be shown on their returns. Failure to maintain
adequate books and records or to substantiate items properly
constitutes negligence. See sec. 1.6662-3(b)(1), Income Tax
Regs.
Notwithstanding petitioners’ belief and testimony that they
made a good-faith effort to determine their income tax liability,
we hold that petitioners are liable for the accuracy-related
penalty as it pertains to the issues described above pertaining
to the disallowed charitable contributions, job expenses, and
section 179 deduction, except as to that portion of the latter
relating to the duplication occasioned by the computer error.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011