Ronald and Nancy Sweet - Page 11




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          for tax year 1988 until June 17, 1997.  The record also shows               
          that respondent did not receive a copy of Form 1099 prior to the            
          commencement of petitioners’ respective audits.  As noted above,            
          we found that petitioners did not substantiate the Schedule C               
          expenses deducted on their 1988 return.  Based on the record, we            
          can find no credible basis for the Schedule C deductions claimed.           
          Petitioner was a tax preparer during the years in issue.  It goes           
          without saying that as a tax preparer petitioner should have                
          understood the substantiation requirements for deductions claimed           
          on their Schedule C.                                                        
               Because petitioners failed to offer any credible explanation           
          for their lack of due care in preparing and filing their 1988               
          return, they are liable for an addition to tax under section                
          6653(a)(1).                                                                 
               We have considered all arguments by the parties, and, to the           
          extent not discussed above, conclude that they are irrelevant or            
          without merit.                                                              
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
                                                  Decisions will be entered           
                                             under Rule 155 in docket No.             
                                             4479-00S and for respondent in           
                                             docket No. 4480-00S.                     








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