- 12 -
(1985). The term "disregard" includes any careless, reckless, or
intentional disregard of rules or regulations. Sec. 6662(c).
Just as with respondent's deficiency determination, his
determination of negligence or intentional disregard of rules or
regulations is prima facie correct, with the burden of proof to
the contrary on petitioner. See Neely v. Commissioner, supra.
Petitioner did not address the section 6662 penalty issue at
trial. Petitioner has failed to carry his burden of proof, and
we sustain respondent's determination of the penalty.
To reflect the foregoing,
Decision will be entered
under Rule 155.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
Last modified: May 25, 2011