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same reasons we found petitioners to be negligent in claiming the
reported loss as a deduction, we would also find petitioners
lacked reasonable cause for doing so. See sec. 6661(c); sec.
1.6661-6(b), Income Tax Regs. We sustain respondent’s
determination that petitioners are liable for the section 6661(a)
addition to tax for a substantial understatement of tax.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
for respondent.
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