Inez Meilak - Page 14

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               Petitioner has failed to demonstrate that she was not                  
          negligent or that she had a reasonable basis for underreporting             
          her tip income.  Petitioner has not satisfied her burden of                 
          proof, and accordingly, is liable for the accuracy-related                  
          penalty under section 6662(a) for both 1989 and 1990.  We must              
          sustain respondent on this issue.                                           
               In conclusion, we have considered all the arguments made by            
          the parties and, to the extent not discussed above, find them to            
          be without merit.  To reflect the foregoing,                                
                                                  Decision will be entered            
                                             for respondent as to the                 
                                             deficiencies and the section             
                                             6662(a) penalties, and for               
                                             petitioner as to the section             
                                             6663(a) penalties.                       





















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