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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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Last modified: May 25, 2011