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shown that there was reasonable cause for such portion and the
taxpayer acted in good faith with respect thereto. See sec.
6664(c)(1).
Petitioner claims that he did not omit any income from his
1995 return, but we have found differently as discussed above.
Otherwise, petitioner offered no evidence to establish that
respondent’s imposition of the negligence penalty is erroneous.
Accordingly, respondent’s determination that petitioner is liable
for the negligence penalty for 1995 is sustained.
Reviewed and adopted as the report of the Small Tax Case
Division.
Based on the foregoing,
Decision will be
entered under Rule 155.
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Last modified: May 25, 2011