Marcel Toto Ngosso - Page 14

                                       - 13 -                                         
               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               
               To reflect the foregoing,                                              

                                             Decision will be entered                 
                                        for respondent.                               

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  

Last modified: May 25, 2011