- 9 - is appropriate, but respondent need not produce evidence regarding reasonable cause. Higbee v. Commissioner, 116 T.C. 438, 446-447 (2001). Petitioner substantially understated his income tax liability for the 1996 taxable year because he reported a income tax liability of zero. Respondent provided the amount and sources of the unreported gross income determined in the 1996 notice of deficiency and the amendment to answer. Petitioner’s income tax liability substantially exceeds the amount shown on his 1996 return. On the record before the Court, we find that respondent has satisfied the burden of production with respect to the accuracy-related penalty under section 6662(a). Petitioner presented no evidence indicating reasonable cause for the understated income. Accordingly, we sustain the imposition of the accuracy-related penalty. Decisions will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011