- 21 - The record in this case does not contain any of the records that Mr. Agbaniyaka testified he maintained.16 On the instant record, we find that petitioners did not maintain the records required by section 6001 and section 1.6001-1(a), Income Tax Regs. On that record, we further find that the burden of production that respondent has under section 7491(c) is satisfied. See sec. 1.6662-3(b)(1) and (2), Income Tax Regs. In support of their position that they are not liable for each of the years at issue for the accuracy-related penalty, petitioners make the following argument on brief: Taxpayers relied upon the knowledge gained by Benjamin as an IRS Revenue Agent. Respondent charac- terizes him as an expert when arguing that he acted negligently in failing to follow the tax code and regulations. Similarly, he should be accorded the benefit of this expertise in claiming deductions which are proper and allowable under the Internal Revenue Code and based on the IRS policy and procedures and that Benjamin is familiar with. On the record before us, we reject petitioners’ argument. During the years at issue, Mr. Agbaniyaka was a trained revenue agent and was fully aware of the requirements imposed by section 6001. Nonetheless, petitioners failed to maintain sufficient records for each of their taxable years 2001 through 2004 to 16The only documentation that petitioners introduced into the record are copies of two American Express Business Gold Card bills that showed a purchase on June 8, 2002, from “IMPORTS OF AFRICA” of $1,200 and a purchase on June 25, 2002, from “IMPORTS OF AFRICA” of $750. Respondent concedes that Mr. Agbaniyaka made those purchases in 2002.Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 NextLast modified: November 10, 2007