Peter Milton Joseph and Ella Joseph, Deceased - Page 26

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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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