- 11 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
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