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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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Last modified: May 25, 2011