- 14 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14
Last modified: May 25, 2011