- 39 - penalty based on a determination that the entire amount of the deficiency is due to petitioners’ negligence. A. Amounts of Deficiency The 1993 deficiency that respondent determined is due entirely to application of the bank deposits method. Supra table 2, especially notes 6 and 7. Our comments and conclusions in the course of our analysis of the bank deposits method in Part II. C., supra, apply equally to 1993. We hold that, except as to respondent’s concessions and our comments in supra table 2, notes 6 and 7, petitioners have failed to show that respondent’s determination of omitted income was excessive. B. Negligence Respondent determined that petitioners are liable for a 20- percent negligence addition to tax on the entire underpayment for 1993. Respondent contends petitioners’ failure to maintain and furnish adequate records of their 1993 income-producing activities “thwarted respondent’s attempt to examine petitioners’ tax liability for that year.” Petitioners maintain that section 6662 does not apply because reasonable cause excuses their failure to report all of their taxable income for 1993.Page: Previous 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 Next
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