- 16 - independent advice regarding the propriety of the deduction. Despite these warnings, petitioners did not seek such advice or conduct any other type of inquiry into the propriety of the deduction. We find that it was negligent for petitioners to have claimed this deduction under the circumstances of this case. We sustain respondent’s determination that petitioners are liable for the section 6653(a)(1) and (2) additions to tax for negligence. Reviewed and adopted as the report of the Small Tax Case Division. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
Last modified: May 25, 2011