Leslie S. Hirahara - Page 17

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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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