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(1985). The term "disregard" includes any careless, reckless, or
intentional disregard. Sec. 6662(c). The penalty does not apply
to any portion of an underpayment for which there was reasonable
cause and with respect to which the taxpayer acted in good faith.
Sec. 6664(c).
Petitioner testified that he is entitled to the deductions
in question; however, his position is not reasonable under the
circumstances. He failed to provide sufficient evidence
regarding a significant portion of his expenses. Petitioner did
not have adequate records and this required our review of each
expense incurred and canceled checks presented at the trial.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011