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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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