- 9 - substantiate them and failed to establish that the amounts were expended for a business purpose. Petitioners knew respondent had questioned their documentation of expenses in prior years. Here, petitioners failed to respond to documentation requests via the IDRs and did not present any evidence at trial to demonstrate their entitlement to additional deductions on their returns. For each of the years in issue, petitioners also claimed earned income credits for their two children of $602 in 1993; $1,506 in 1994; and $1,860 in 1995. Respondent determined petitioners were not eligible to claim these credits, and petitioners knew respondent had denied their claimed earned income credits in prior years. D. Additions to Tax and Penalties Respondent determined that petitioners are liable for additions to tax under section 6651(a)(1) for failure to file timely their tax returns for 1993 and 1994. For each of the years in issue, respondent also determined that petitioners are liable for an accuracy-related penalty under section 6662(a). Discussion Respondent's determinations in the notice of deficiency are presumed correct, and generally, petitioners bear the burden of proving that respondent's determination of income taxPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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