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proper tax liability and the knowledge and experience of the
taxpayer. Sec. 1.6664-4(b)(1), Income Tax Regs.
Petitioner makes no argument concerning respondent's deter-
mination under section 6662(a) except for his claim, which we
have rejected, that he and Ms. Croteau did not intend that the
terms of the agreement control the payments at issue. Based on
our examination of the entire record before us, we find that
petitioner has failed to show that he acted with reasonable cause
and in good faith, or that he otherwise exercised due care or
made a reasonable attempt to comply with the Internal Revenue
Code, when he claimed the alimony deduction at issue. Accord-
ingly, we sustain respondent's determination imposing the
accuracy-related penalty under section 6662(a) for 1993.
To reflect the foregoing,
Decision will be entered
for respondent.
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