- 5 - Commissioner, 85 T.C. 934, 947 (1985) (quoting Marcello v Commissioner, 380 F.2d 499, 506 (5th Cir. 1967), affg. in part and remanding in part 43 T.C. 168 (1964)). Petitioner has failed to establish that she exercised due care in reporting her income and expenses, Bixby v. Commissioner, 58 T.C. 757, 791 (1972), or that she acted with reasonable cause and in good faith, sec. 6664(c). Accordingly, petitioner is liable for the section 6662 accuracy-related penalties. All other arguments raised by the parties are either irrelevant or without merit. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 1 2 3 4 5
Last modified: May 25, 2011