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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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