15
Code. Sec. 6662(c). "Disregard" includes any careless,
reckless, or intentional disregard. Id. The failure to maintain
adequate records may constitute negligence. Zafiratos v.
Commissioner, T.C. Memo. 1992-135, affd. without published
opinion 993 F.2d 880 (3d Cir. 1993).
Petitioner did not present any evidence to establish that
the accuracy-related penalty should not apply. Respondent is
sustained on this issue.
To reflect the foregoing,
Decision will be entered
under Rule 155.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Last modified: May 25, 2011