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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 tax
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