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to any part of an underpayment if the taxpayer shows that there
was reasonable cause for that part and that the taxpayer acted in
good faith. Sec. 6664(c)(1).
Petitioner has not proven that the deficiency in income tax
for 1991 was not due to negligence or intentional disregard of
rules or regulations. Petitioner did not argue that he is not
liable for the accuracy-related penalty for substantial
understatement for 1992. We conclude that petitioner is liable
for the accuracy-related penalty under section 6662(a) for 1991
and 1992.
To reflect the foregoing,
Decisions will be entered
under Rule 155.
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