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related penalty in an amount equal to 20 percent of the portion
of the underpayment of tax attributable to negligence or
disregard of rules or regulations. Sec. 6662(a) and (b).
Section 1.6001-1(a), Income Tax Regs., requires taxpayers to keep
adequate records of their deductions and expenses. Petitioner
disregarded this regulation. In addition, petitioner failed to
exercise due care in claiming a tax credit for the alleged
purchase of 99,000 gallons of gasoline. Accordingly, petitioner
is liable for the accuracy-related penalty.
All other contentions raised by the parties are either moot
or without merit.
To reflect the foregoing,
Decision will be entered
pursuant to Rule 155.
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Last modified: May 25, 2011