- 21 -
Petitioners contend that they believed in good
faith that the expenses they claimed were allowable. Good
faith on the part of taxpayers, however, does not always negate
negligence. Taxpayers are required to take reasonable steps to
determine the law and to comply with it. Niedringhaus v.
Commissioner, 99 T.C. 202, 222 (1992). In this case,
petitioners have not shown that their claimed deductions for
expenses were made with any significant regard to whether they
were personal in nature, and the record supports the inference
that petitioners’ photography activity was used to deduct
personal expenses. For the foregoing reasons, moreover, we do
not consider Mr. Storer to have acted reasonably with respect to
the deduction of those expenses claimed for his photography
activity. Based on our consideration of the entire record, we
sustain respondent’s determinations with respect to the accuracy-
related penalties for negligence for the years in issue.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: November 10, 2007