- 12 -
the "lack of due care or failure to do what a reasonable and
ordinarily prudent person would do under the circumstances."
Neely v. Commissioner, 85 T.C. 934, 947 (1985). Section 6001
provides that a taxpayer has an obligation to maintain adequate
books and records.
Petitioner did not maintain adequate books and records and
failed to exercise due care in reporting his income.
Accordingly, we hold that he is liable for the section 6653(a)
addition to tax and section 6662 accuracy-related penalties.
All other arguments raised by the parties are either
irrelevant or without merit.
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
Last modified: May 25, 2011