- 30 - 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 toPage: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
Last modified: May 25, 2011