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Further, petitioner attempted to deduct numerous personal
expenses as business expenses without any basis in fact or law.
Petitioner is an accountant who presumably is familiar with the
provisions of the Internal Revenue Code applicable to his case,
particularly the recordkeeping requirements; yet he disregarded
the applicable law in preparing his Federal income tax return.
On the basis of the entire record, we conclude petitioner has not
established that the underpayment was due to reasonable cause or
that he acted in good faith. Accordingly, we hold petitioner is
liable for the accuracy-related penalty.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be
entered under Rule 155.
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