Jerry J. and Susan N. LeBouef - Page 23




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          Schedule C gross receipts and cost of goods sold were based on              
          oral representations of petitioners’ bookkeeper.  No indication             
          has been given as to what documentation led to the partnership              
          loss deduction.  The record is silent as to petitioners’ personal           
          role in supplying information.  We do not know whether                      
          petitioners, before signing their Form 1040, even questioned                
          their preparer as to why an allegedly inoperative business was              
          returned in such a manner.  In sum, we cannot with any confidence           
          say that petitioners took reasonable care in attempting to                  
          ascertain their proper tax liability.  We hold that petitioners             
          are liable for the section 6662(a) accuracy-related penalty.                
               To reflect the foregoing,                                              


                                                  Decision will be entered            
                                             for respondent.                          






















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