- 14 - and circumstances. McCallson v. Commissioner, T.C. Memo. 1993- 528; sec. 1.6664-4(b)(1), Income Tax Regs. Petitioners must show that they were not negligent. Cluck v. Commissioner, 105 T.C. 324, 339 (1995). Petitioners failed to establish that they were not negligent in failing to retain documentation for their itemized deductions. They have failed to carry their burden of proof. We sustain respondent’s determination that they are liable for the accuracy-related penalty for 2001. Reviewed and adopted as the report of the Small Tax Case Division. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Last modified: May 25, 2011