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At trial petitioner was unable to provide detailed and
reliable testimony concerning the deposits in and withdrawals
from his bank accounts. Petitioner’s testimony concerning his
income from tax return preparation and the currency exchange
transactions was, at best, vague and inconsistent, and his
testimony concerning support for Shanita was not credible or
supported by any documentary evidence. He did not maintain
records or accurately report his gross income. We are further
satisfied that respondent’s reconstruction of petitioner’s income
was reasonable. We conclude that his underpayment is
attributable to negligence and disregard of the rules or
regulations, and petitioner has not shown reasonable cause or
that he acted in good faith with respect to the underpayments.
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