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the accuracy-related penalty under section 6662(a) as imposed by
respondent. Respondent has satisfied his burden of production
under section 7491(c). Higbee v. Commissioner, 116 T.C. 438,
446-447 (2001). Petitioner has failed to provide any reasonable
explanation or credible evidence to substantiate entitlement to
the claimed deductions. Such actions are not those of a
reasonable and prudent person under the circumstances.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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Last modified: May 25, 2011