- 12 - interests in mind. The fact remains, however, that petitioners failed to establish how the expenses at issue were directly related to either petitioner’s trade or business of earning income as an educator, and were, in certain instances, explicitly not deductible by operation of statute. See sec. 274(a)(3), (m)(2); sec. 1.274-2(a)(2)(iii)(a), Income Tax Regs. Petitioners also did not consult a professional tax advisor. While apparently motivated by a desire to enhance the education of their students, petitioners have failed to show reasonable cause for the underpayment caused by petitioners’ claimed expenses. We therefore sustain respondent's determination regarding the accuracy-related penalty under section 6662(a). To reflect the concessions of the parties, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13
Last modified: May 25, 2011