- 9 - Petitioner has practiced law for many years and was aware of the requirement that complete and accurate books and records be maintained with respect to the financial activities of NTG. Petitioner did not present any evidence nor did he make any argument as to why the penalty for negligence should not apply to the disallowed $35,000 partnership loss deduction. Although neither petitioner nor respondent made any specific argument as to whether the penalty for negligence should apply to the other adjustments that have been agreed upon, those other adjustments were settled largely in a manner favorable to petitioner. We conclude that petitioner is liable for the penalty for negligence only with respect to the portion of the income tax deficiency attributable to the claimed $35,000 NTG partnership loss. Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011