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including the experience, knowledge, and education of the
taxpayer.” Neely v. Commissioner, 85 T.C. 934 (1985).
It is the taxpayer’s responsibility to establish that he is
not liable for the accuracy-related penalty imposed by section
6662(a). Rule 142(a); Tweeddale v. Commissioner, 92 T.C. 501,
505 (1989).
On the basis of the entire record, we conclude petitioner
has not established that the underpayment was due to reasonable
cause or that petitioner acted in good faith. Accordingly, we
hold petitioner is liable for the accuracy-related penalties.
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