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It might have been office supplies; it might have
been computer expense. It was an error in terms of how
it was grouped when the check was disbursed or was
recorded into the general ledger.
The totality of the evidence supports the conclusion that
petitioner willfully disguised personal expenses as business
expenses in order to claim deductions that he knew were improper.
He and his preparer ignored applicable statutes, including but
not limited to sections 262, 274, 280A, and 6001, and the
applicable regulations. The accuracy-related penalty is fully
justified on the record in this case.
To reflect respondent’s concessions,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011