- 16 -
To reflect the foregoing,
Decision will be
entered in accordance with
respondent's computation under
Rule 155.
***(...continued)
fact that petitioner was not negligent on his reporting position
does not obviate the increased rate of interest under sec. 6621,
or the delinquency addition under sec. 6651. Although the
Commissioner may waive the applicability of sec. 6661 for
reasonable cause and good faith, see sec. 6661(c), she can only
do so after the taxpayer presents his or her claim to the
Commissioner with sufficient evidentiary support, see, e.g.,
McCoy Enters., Inc. v. Commissioner, 58 F.3d 557 (10th Cir.
1995), affg. on this issue T.C. Memo. 1992-693; see also Brown v.
Commissioner, T.C. Memo. 1992-15. The record does not show that
petitioner ever presented respondent with any type of a claim for
a waiver under sec. 6661(c).
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Last modified: May 25, 2011