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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.
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