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2003 returns. They claimed deductions for travel expenses that
were improperly calculated using per diem rates without
maintaining records of the dates, places, and business activity
of the travel. They did not produce records of the purchase
prices of the farms or valid appraisals of the land and buildings
at the time of the purchases. They did not seek professional
advice. Petitioners have not shown that their underpayments
were due to reasonable cause. Accordingly, we hold that
petitioners are liable for accuracy-related penalties under
section 6662(a) for 2001, 2002, and 2003.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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