- 11 - Petitioner testified that he prepared his own returns for 1992 and 1993. He failed, however, to maintain adequate records to substantiate the amounts claimed on his return. Based on the record, we hold that petitioner has not proved that his underpayment was due to reasonable cause or that he acted in good faith. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11
Last modified: May 25, 2011