- 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 decisionPage: Previous 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 Next
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