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in good faith in, claiming a deduction for Mr. Horwath’s 1998
travel expenses in petitioners’ 1998 return.
On the record before us, we find that petitioners have
failed to show that they were not negligent and did not disregard
rules or regulations within the meaning of section 6662(b)(1), or
otherwise did what a reasonable person would do, with respect to
the underpayment for each of the taxable years at issue. On that
record, we further find that petitioners have failed to show that
they acted with reasonable cause, or in good faith, with respect
to each such underpayment. See sec. 6664(c)(1). On the record
before us, we find that petitioners have failed to establish that
they are not liable for the accuracy-related penalty under
section 6662(a) for each of the taxable years at issue.10
We have considered all of the contentions and arguments of
the parties that are not discussed herein, and we find them to be
without merit, irrelevant, and/or moot.11
10We have found that petitioners are liable for each of the
taxable years at issue for the accuracy-related penalty under
sec. 6662(a) because of negligence or disregard of rules or
regulations under sec. 6662(b)(1). In light of that finding, we
shall not address respondent’s alternative argument that peti-
tioners are liable for each of the taxable years at issue for the
accuracy-related penalty under sec. 6662(a) because of a substan-
tial understatement of income tax under sec. 6662(b)(2).
11Petitioners advance certain contentions and arguments
relating to the ownership of the computer simulator and SDC’s
alleged transfer by gift of the computer simulator to TGC. We do
not address those contentions and arguments because, even if we
were to accept them, on the instant record we nonetheless reject
(continued...)
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