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tax returns except for the State income taxes previously
mentioned herein. Therefore, he is liable for the accuracy-
related penalty pursuant to section 6662(c), which defines
negligence as the failure to make a reasonable attempt to comply
with the tax law. Hamdi v. Commissioner, T.C. Memo. 1993-38,
affd. without published opinion 23 F.3d 407 (6th Cir. 1994);
Dillon v. Commissioner, T.C. Memo. 1993-11.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011