- 14 - his accountants was not reasonable. Therefore, petitioner has not shown reasonable cause for his failure to include the receipt of the Ranch in income. Accordingly, petitioner is liable for the accuracy-related penalty pursuant to section 6662(a) as determined by respondent. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14
Last modified: May 25, 2011