Kenneth Andrew Baratelle - Page 21




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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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