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explanations with respect to these items were vague and at times
nonsensical.
Petitioner failed to establish that the errors made on his
1993 Federal income tax return were due to reasonable cause.
Consequently, respondent’s determination that petitioner is
liable for the negligence penalty for 1993 is sustained.
Based on the foregoing,
Decision will be
entered for respondent.
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Last modified: May 25, 2011