Peter Spuler, Jr. - Page 11

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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               
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             for respondent.                          

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