Kenneth G. Schladweiler - Page 18

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          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 Schedules C for the           
          years at issue.  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 accuracy-                
          related penalties under section 6662(a) for any year in issue for           
          which he is liable for a deficiency, in amounts to be calculated            
          in accordance with this opinion.                                            
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             under Rule 155.                          

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