Rilwan Adisa Salami - Page 11

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               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.                          





























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