- 16 - not authorized by law (such as transportation for charitable purposes) show a pattern of negligence and disregard of the applicable rules or regulations. Petitioners were put on notice during the audit of their 1991 income tax return that they were not entitled to deductions for estimated expenses or for expenses that were not substantiated by receipts and records. Petitioners are well-educated individuals who knew or should have known that proper record keeping is essential to their entitlement to deductions. Petitioner testified at trial that he was aware of the record keeping obligations, that he was too busy to comply with them, and that he would not change his methodology. With respect to the claimed investment deductions for expenses of the mutual funds, petitioners ignored information in their annual reports that showed that income was reported on a net basis and that they were not entitled to a deduction for the operating expenses. Petitioners claimed the deductions mentioned above without consulting an accountant or attorney. Their actions are not the actions of reasonable and ordinarily prudent persons. Thus, petitioners are liable for penalties under section 6662(a) for both years in issue. We have considered all remaining arguments made by petitioners for a result contrary to that expressed herein, and, to the extent not discussed above, they are irrelevant or without merit.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011