- 38 -
omitted gross income for 1989 and 1990, or that he had reasonable
cause to do so. Accordingly, respondent's determination that
petitioner is liable for the accuracy-related penalty for
negligence for those years must be sustained. The correct amount
of the section 6662(a) accuracy-related penalties for 1989 and
1990 will be calculated in a Rule 155 proceeding.
We have considered all other arguments advanced by the
parties and found them to be either irrelevant or without merit.
IV. Conclusion.
The record contains credible testimony that petitioner's
reputation for truthfulness and veracity in the Springfield,
Kentucky, community is good. Nevertheless, based on our
observations at trial and all of the evidence in the record, we
are forced to conclude that there is a substantial lack of candor
in petitioner's explanation as to how, when, and from what source
he came into possession of the alleged large cash hoard that is
the focus of this case. It is not the Court's function to
speculate as to the actual source of this money, and we decline
the opportunity to do so. We simply do not accept petitioner's
version of the truth.
To reflect the foregoing and concessions,
An appropriate order
will be issued, and decision
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