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Commissioner, 52 T.C. 147, 151 (1969). To qualify for a bad debt
deduction, a taxpayer must show that “some event occurred during
the year in which the deduction is sought that rendered the debt
uncollectible.” Greenberg v. Commissioner, T.C. Memo. 1992-292.
The law and the facts do not support petitioners’ claim to
this bad debt deduction. Among other things, petitioners have
not proven: (1) That the amount of the loan was uncollectible
from the acquaintance or (2) that the equity in the condominium
which Mr. Peacock received did not exceed the loan balance. We
sustain respondent’s denial of this deduction.
3. Accuracy-Related Penalties and Addition to Tax
Respondent determined that petitioners are liable for
accuracy-related penalties under section 6662(a) for, among other
things, negligence and intentional disregard of rules or
regulations. Petitioners argue that they reasonably believed
that the fishing activity was a business and that they reasonably
relied upon their tax return as prepared by their accountant.
Section 6662(a) and (b)(1) imposes a 20-percent
accuracy-related penalty on the portion of an underpayment that
is due to negligence or intentional disregard of rules or
regulations. Negligence includes a failure to attempt reasonably
to comply with the Code. Sec. 6662(c). Disregard includes a
careless, reckless, or intentional disregard. Id. An
underpayment is not attributable to negligence or disregard to
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