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assess the proper tax liability, considering the experience,
knowledge, and education of the taxpayer. Sec. 1.6664-4(b)(1),
Income Tax Regs.
Petitioner is an accountant and lawyer. He represents
clients before the IRS and is a member of this Court’s bar. He
is conversant with section 183 and the regulations. Despite all
this, petitioners deducted farm losses even though petitioner
still had not manifested an actual and honest objective of making
a profit from the farm during 1998 and 2000. We find that
petitioners did not act in good faith in claiming Schedule F
farming losses and their underpayments were not due to reasonable
cause. Petitioners disregarded rules or regulations by deducting
the net losses from the farm. We conclude that petitioners are
liable for the accuracy-related penalty under section 6662(a) for
the underpayments of tax in 1998 and 2000.
To reflect the foregoing,
Decision will be entered
for respondent for 1998 and
2000, and for petitioners for
1999.
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