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to maintain adequate books and records and to act with ordinary
business care and prudence in complying with the Federal income
tax requirements.
On the basis of the entire record, we find that petitioner
was negligent and hold that petitioner is liable for an accuracy-
related penalty under section 6662(a) for the 1995 tax year.
We have considered all arguments made by the parties, and,
to the extent not discussed above, conclude they are irrelevant
or without merit.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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Last modified: May 25, 2011