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depreciable basis in St. Rose Manor. Neither Mr. Hunt nor Mr.
Lopez prepared petitioners’ returns after 1992, and petitioners
offered no explanation for this overstatement. Petitioners did
not establish that the underpayment of taxes was due to errors by
their representatives and not due to errors on their part.
Petitioners did not demonstrate that they supplied accurate
information to their representatives for purposes of preparing
the relevant returns. See Xuncax v. Commissioner, supra.
Petitioners have not shown that they are entitled to relief under
section 6664(c)(1). We sustain the accuracy-related penalties as
determined.
Decision will be
entered for respondent.
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