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due to negligence or disregard of rules or regulations. Sec.
6662(b). Whether applied because of a substantial understatement
of tax or negligence or disregard of the rules or regulations,
the accuracy-related penalty is not imposed with respect to any
portion of the understatement as to which the taxpayer acted with
reasonable cause and in good faith. Sec. 6664(c)(1). The
decision as to whether the taxpayer acted with reasonable cause
and in good faith depends upon all the pertinent facts and
circumstances. Sec. 1.6664-4(b)(1), Income Tax Regs.
Petitioner conceded he did not report $168,948 of taxable
income in 1992. We have found that petitioner did not report an
additional $229,055 of income for 1992. Petitioner’s only
argument is that he should not be penalized because he “was naive
and stupid”.
We conclude that petitioner is liable for a penalty pursuant
to section 6662 for 1992.
In reaching all of our holdings herein, we have considered
all arguments made by the parties, and to the extent not
mentioned above, we find them to be irrelevant or without merit.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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