Keith Robert Bradbury - Page 11

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          underpayment that is attributable to negligence or disregard of             
          rules or regulations.  Under section 6662(c), negligence includes           
          any failure to make a reasonable attempt to comply with the law             
          and the term "disregard" includes any careless, reckless, or                
          intentional disregard.  Failure to maintain adequate records may            
          constitute negligence.  Schroeder v. Commissioner, 40 T.C. 30, 34           
          (1963); Johnson v. Commissioner, T.C. Memo. 1991-346, affd.                 
          without published opinion 8 F.3d 811 (3d Cir. 1993).                        
               As noted, it is the responsibility of petitioner to maintain           
          books and records sufficient to accurately establish the amount             
          of his deductions.  Sec. 6001.  Petitioner failed to maintain               
          organized records and receipts of the expenses claimed on his               
          returns for the years at issue, clearly claimed deductions for              
          items of a personal nature, and did not present any evidence with           
          respect to his liability for the above addition and penalty.  We            
          conclude that petitioner is liable for the addition to tax under            
          section 6653(a) and the accuracy-related penalty under section              
          6662 as determined by respondent.                                           
                                                  Decision will be entered            
                                             for respondent.                          













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