- 23 - 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.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