- 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