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Based on the record, we find that petitioner failed to make a
reasonable attempt to comply with the provisions of the Internal
Revenue laws. Petitioners's lack of substantiation and the
unexplained inconsistency in his testimony about the child care
expenses claimed compel us to find petitioner liable for the
accuracy-related penalty. Accordingly, respondent will be
sustained on this issue.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011