Norman John Haas III and Susan Renee Haas - Page 15

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         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.                           






















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