Emmanuel I. Nwachukwu - Page 16




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               Petitioner was employed as a tax auditor for the State of              
          California and had a college degree in finance.  Therefore,                 
          petitioner is aware, or should be aware, of the importance of               
          maintaining adequate records and documenting expenditures.                  
               Considering all the facts, we find petitioner was negligent            
          and disregarded rules and regulations in preparing his 1995                 
          return.  Thus, we sustain respondent's determination that                   
          petitioner is liable for the accuracy-related penalty on the                
          amount of the underpayment for 1995.                                        
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             under Rule 155.                          



























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