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records of his interest income or that he accurately reported
such income.
Insofar as petitioner's unreported self-employment income is
concerned, we have already commented on petitioner's small, red,
spiral notebook and sustained respondent's determination that
petitioner failed to report $12,670 of self-employment income.
Thus, it cannot be said that petitioner maintained accurate
records of his self-employment income or that he accurately
reported such income.
Finally, the record does not demonstrate that petitioner
made a good faith effort to assess his proper tax liability for
1991.
In view of the foregoing, we sustain respondent's
determination and hold that petitioner is liable for the
accuracy-related penalty under section 6662(a).
Conclusion
To reflect the foregoing,
Decision will be entered
for respondent.
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