Gregory C. Welton - Page 3

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          expenses related to a trade or business, or income-producing                
          activity.  Accordingly, we sustain respondent's determination.              
               Respondent determined that Mr. Welton is liable for an                 
          accuracy-related penalty pursuant to section 6662(a).  The                  
          penalty applies to any portion of Mr. Welton's underpayment that            
          is attributable to negligence or disregard of the rules or                  
          regulations.  See sec. 6662(b)(1).  Mr. Welton failed to                    
          establish that he exercised due care in reporting his expenses.             
          Accordingly, we sustain respondent's determination.                         
               Contentions that we have not addressed are either                      
          irrelevant, moot, or meritless.                                             
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                        under Rule 155.                               





















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