Don E. Kramer - Page 15




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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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