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taxpayer is not liable for the penalty if he shows that he had
reasonable cause for the underpayment and that he acted in good
faith. See sec. 6664(c).
Petitioner failed to maintain adequate records to
substantiate the deductions he claimed on his 1994 Schedule C.
See sec. 6001; sec. 1.6001-1(a), Income Tax Regs. He offered no
evidence at trial to explain this failure. Accordingly, we hold
that petitioner is liable for an accuracy-related penalty under
section 6662(a) for 1994 in an amount to be calculated in
accordance with this opinion.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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