- 9 -
result, have acknowledged that an underpayment exists for each
such year. Petitioners offered no evidence, and advance no
argument, under section 6662 with respect to their return treat-
ment for the years at issue of (1) the various items as to which
respondent made determinations that petitioners conceded and
(2) the expenditures in question as to which respondent made
determinations that we sustained.5 On the instant record, we find
that the burden of production that respondent has under section
7491(c) is satisfied.
On the instant record, we find that petitioners have failed
to carry their burden of showing that they were not negligent and
did not disregard rules or regulations, or otherwise did what a
reasonable person would do, with respect to the underpayment for
each of the years at issue.
On the instant record, we further find that petitioners have
failed to carry their burden of showing that there was reasonable
cause for, and that they acted in good faith with respect to, the
underpayment for each of the years at issue. See sec.
6664(c)(1).
On the record before us, we find that petitioners have
failed to carry their burden of establishing that they are not
liable for each of the years at issue for the accuracy-related
5The record does not show that any records that petitioners
maintained were sufficient under sec. 6001 and sec. 1.6001-1(a),
Income Tax Regs. See sec. 1.6662-3(b)(1), Income Tax Regs.
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: November 10, 2007