- 22 - unsuccessful experience with Amway. Additionally, respondent has shown that petitioners failed to substantiate their claimed charitable contribution deductions. These circumstances show that respondent has met his burden of production for his determination of the accuracy-related penalty based on negligence. Also, with regard to that determination, petitioners have failed to meet their burden of proof that they acted with reasonable cause and in good faith. On this record, we find that petitioners have failed to demonstrate that they were not negligent and also have failed to show that they did not disregard applicable rules or regulations. They have not shown that there was reasonable cause for their underpayment or that they acted in good faith. Accordingly, we sustain respondent’s imposition of the accuracy-related penalty under section 6662(a) for 1997. Reviewed and adopted as the report of the Small Tax Case Division. Decision will be entered for respondent.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23
Last modified: May 25, 2011