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reasonable attempt to comply with the provisions of the Internal
Revenue Code and defines "disregard" as including any careless,
reckless, or intentional disregard. However, under section
6664(c), the penalty under section 6662(a) shall not be imposed
with respect to any portion of the underpayment if it is shown
that there was reasonable cause for the underpayment, and the
taxpayer acted in good faith.
Petitioner failed to present any evidence to show reasonable
cause why he should not be held liable for the penalty under
section 6662(a). Moreover, the record shows that petitioner's
activity was far from being a for-profit activity, and petitioner
was negligent in claiming a substantial loss from that activity.
Accordingly, respondent is also sustained on this issue.
Decision will be entered
for respondent.
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Last modified: May 25, 2011