Dorothy A. Wilson - Page 11




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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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