- 26 - background and reliance, we hold that his actions with respect to that item were reasonable and are not subject to the section 6662 penalty. With respect to the substantiation items and any items conceded, petitioner has failed to show that his actions were reasonable and not careless, reckless, or made with intentional disregard of rules or regulations. Even considering petitioner’s background, his inability to substantiate claimed expenditures is not reasonable. Under these circumstances, we hold that petitioner is liable, in each of the 3 taxable years, for the accuracy-related penalty under section 6662(a) on the portion of any underpayment attributable to the substantiation issues decided and on the adjustment items that he conceded. To reflect the foregoing and due to concessions, Decision will be entered under Rule 155.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26
Last modified: May 25, 2011