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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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