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substantiation. Petitioner makes no other argument that he is
not liable for the accuracy-related penalty under section
6662(a). We conclude that petitioner is liable for the accuracy-
related penalty for each of the years in issue.
C. Whether Respondent Should Be Sanctioned
Petitioner contends that we should sanction respondent
because he alleges that respondent violated his procedural rights
under sections 6001, 6011, 6012(a), and 6703(a), IRS Publication
1, “Your Rights as a Taxpayer”, and IRS Privacy Act Notice 609 by
failing to explain a document relating to his 1993 tax year
(which is not before the Court) and by refusing to settle this
case. We disagree. Petitioner has not shown that respondent
violated his rights in any way. We conclude that sanctions are
not appropriate on this record.
To reflect the foregoing,
Decision will be
entered for respondent.
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