- 14 - We sustain respondent's determination on this issue.5 Although petitioner asks us to allow him some deductions to offset this income, we decline to do so. Petitioner must prove his entitlement to any deduction, and he must keep sufficient records to substantiate any deduction that he claims. Sec. 6001; New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934). Petitioner has not introduced any evidence to substantiate his entitlement to any deductions, and the record does not persuade us that petitioner is entitled to any deductions. Respondent also determined that petitioner was liable for an accuracy-related penalty under section 6662(a) because he substantially understated his Federal income tax. See sec. 6662(b)(2). As relevant herein, section 6662(a) imposes an accuracy-related penalty equal to 20 percent of an underpayment that is due to a substantial understatement of income tax. Petitioner will avoid this penalty if the record shows that his income tax was not understated by the greater of 10 percent of the tax required to be shown on the return or $5,000. Sec. 6662(d)(1)(A). The accuracy-related penalty of section 6662 is not applicable to any portion of an underpayment to the extent that an individual has reasonable cause for that portion and acts in good faith with respect thereto. Sec. 6664(c)(1). Such a determination is made by taking into account all facts and 5 Petitioner has not challenged respondent's determination that this income is subject to self-employment tax. We sustain that determination without further comment. See Rule 142.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011