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On the record before us, we find that petitioner has failed
to show that there was reasonable cause and that he acted in good
faith when he did not report the $1,623,203 settlement payment as
income in his 1994 tax return.7
We have considered all of the contentions and arguments of
petitioner that are not addressed herein, and we find them to be
without merit and/or irrelevant.
To reflect the foregoing and the concessions of the parties,
Decision will be entered
under Rule 155.
7We find no basis whatsoever on the record before us for
petitioner's position that the entire $1,623,203 settlement
payment was paid to him on account of the loss of his business
reputation and the loss of his reputation as an orchid grower.
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