- 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.
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Last modified: May 25, 2011