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there was a reasonable cause for such portion and that the
taxpayer acted in good faith with respect to such portion. Sec.
6664(c).
On this record, we conclude that petitioners are liable for
the accuracy-related penalty under section 6662(a) as imposed by
respondent. Petitioners have failed to provide any reasonable
explanation or credible evidence to substantiate entitlement to
the claimed deductions. Such actions are not those of a
reasonable and prudent person under the circumstances.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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Last modified: May 25, 2011