- 26 - unreported income, was not properly determined by respondent. Even had petitioners contended that this penalty was not properly determined by respondent, we find nothing in the record to support such a contention. Respondent has shown that petitioners did not keep adequate books and records to properly substantiate their items claimed on their return, and thus petitioners failed to make a reasonable attempt to comply with the provisions of the Internal Revenue Code. Therefore, we find that petitioners were negligent in their filing of their tax return which reported an incorrect tax. Thus, we sustain respondent’s determination with respect to the section 6662(a) accuracy-related penalty. To reflect the foregoing, An appropriate order and decision will be entered under Rule 155.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26
Last modified: May 25, 2011