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affd. on other grounds 501 U.S. 868 (1991). The question then is
whether petitioners’ conduct meets the reasonably prudent person
standard. See id.
We do not believe that petitioners’ conduct meets this
standard. The law surrounding the disputed items is not complex.
With respect to the claimed deductions, petitioners were required
to maintain records, which they failed to do. Furthermore, there
is no indication that petitioners sought the advice of a
qualified tax advisor concerning any of the disputed items. We
sustain respondent’s determination.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011