Henry C. Boler and Sherry M. Boler - Page 23




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          Thus, petitioners have not met the requirements of section                  
          274(d).  Thus, we conclude that AIM may not deduct the coded                
          expenses of $1,254, $600, and $480.                                         
               Respondent conceded that the coded expenses of $600 and $480           
          are for lodging expenses of AIM’s employees other than the Bolers           
          and thus are not constructive dividends to petitioner.  However,            
          we conclude that the coded expense of $1,254 is a constructive              
          dividend to petitioner because petitioners have not shown                   
          otherwise.                                                                  
          I.   Whether Petitioners Are Liable for the Accuracy-Related                
               Penalty Under Section 6662(a) for Negligence                           
               Petitioners contend that they are not liable for the                   
          accuracy-related penalty for negligence under section 6662(a)               
          because they reasonably relied on their accountants.  They also             
          contend that they had an honest misunderstanding of the law as to           
          all issues.                                                                 
               Petitioners are not liable for the accuracy-related penalty            
          for negligence with respect to matters on which they prevailed              
          here.  They are also not liable for the accuracy-related penalty            
          with respect to the $17,532 AIM claimed as costs of goods sold              
          because they are inexperienced in tax accounting matters and they           
          reasonably relied on the advice of two accountants on this issue.           
          We conclude, however, that petitioners were negligent with                  
          respect to:  (1) The disallowed interest deductions; (2) the                







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