- 18 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18
Last modified: May 25, 2011