John Weller Wood, Jr., and Magdalena Frances Wood - Page 37

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          as to the tax treatment of an item may meet this requirement.               
          Sec. 1.6664-4(b), Income Tax Regs.                                          
               Petitioner has made no showing that he made a reasonable               
          attempt to comply with the tax rules and regulations with regard            
          to those deductions he took for the years at issue which have               
          been disallowed.  Hence, with respect to those deductions,                  
          petitioner has failed to show that he was not negligent.                    
          Moreover, petitioner has not shown that he acted in good faith              
          with respect to, or that there was reasonable cause for, the                
          position he took.  Further, petitioner does not claim that he               
          relied on a tax professional as to the tax treatment of the                 
          expenses and losses at issue, including those related to his                
          personal residences.  Petitioner simply asserts that the                    
          accuracy-related penalty does not apply because he properly                 
          claimed the deductions under section 162(a).  We have found to              
          the contrary.                                                               
               Under these circumstances, we are compelled to hold that               
          petitioner is liable for the accuracy-related penalty for the               
          years at issue.                                                             














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