- 13 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13
Last modified: May 25, 2011