- 17 - (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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
Last modified: May 25, 2011