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947 (1985). Disregard includes any careless, reckless, or
intentional disregard of rules or regulations. See sec. 6662(c);
sec. 1.6662-3(b)(2), Income Tax Regs. No penalty will be imposed
with respect to any portion of any underpayment if it is shown
that there was reasonable cause for such portion and that the
taxpayer acted in good faith with respect to such portion. See
sec. 6664(c).
Based on this record, we conclude that petitioner is liable
for the accuracy-related penalties under section 6662(a).
Petitioner’s returns for the years in issue were replete with
errors, and petitioner failed to provide credible evidence to
substantiate or support entitlement to the deductions claimed.
We conclude that petitioner’s actions were not those of a
reasonable and prudent person under the circumstances. Thus, we
sustain respondent on this adjustment.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011