Anthony Muhammad - Page 7

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          is nothing in the record regarding the amounts or dates of the              
          individual contributions that comprise those amounts.                       
               We find that petitioner failed to provide reliable evidence            
          of his purported contributions and failed to meet his burden of             
          proof.  We hold that respondent’s determinations disallowing                
          petitioner’s claimed charitable contribution deductions are                 
          sustained.                                                                  
          2.   Section 6662(a)                                                        
               With respect to the accuracy-related penalty under section             
          6662(a), the Commissioner has the burden of production.  Sec.               
          7491(c).  To prevail, the Commissioner must produce sufficient              
          evidence that it is appropriate to apply the penalty to the                 
          taxpayer.  Higbee v. Commissioner, 116 T.C. 438, 446 (2001).                
          Once the Commissioner meets his burden of production, the                   
          taxpayer bears the burden of supplying sufficient evidence to               
          persuade the Court that the Commissioner’s determination is                 
          incorrect.  Id. at 447.                                                     
               Section 6662(a) provides an accuracy-related penalty equal             
          to 20 percent of the underpayment required to be shown on a                 
          return due to negligence or disregard of rules or regulations.              
          Sec. 6662(b)(1).  For purposes of section 6662, the term                    
          “negligence” includes “any failure to make a reasonable attempt             
          to comply with the provisions of * * * [the Code], and the term             
          ‘disregard’ includes any careless, reckless, or intentional                 






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