- 20 - Nothing in the record indicates that petitioners used the Corona property or their Schedule C activities to derive personal pleasure or recreation. Consequently, this factor weighs in favor of finding a profit motive. To conclude, after giving due consideration to the record as a whole, we find that during the years in issue, petitioners did not carry on their Schedule C activities with an intent to make a profit. Accordingly, we sustain respondent’s disallowance of petitioners’ Schedule C losses. Section 6662(a) Accuracy-Related Penalty We next consider whether petitioners are liable for the section 6662(a) accuracy-related penalties for the years in issue. Section 6662 imposes a penalty equal to 20 percent of any portion of an underpayment of tax that is attributable to negligence or disregard of rules or regulations or to a substantial understatement of tax. See sec. 6662(a), (b)(1), and (b)(2). “Negligence” includes any failure of the taxpayer to make a reasonable attempt to comply with the provisions of the Internal Revenue Code, and “disregard” includes any careless, reckless, or intentional disregard of the Internal Revenue Code or its rules or regulations. Sec. 6662(c). The accuracy-related penalty will be imposed unless the taxpayers can demonstrate that they acted in good faith and with reasonable cause with respect to thePage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011