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ment for the year at issue. See sec. 6664(c)(1). On the record
before us, we find that petitioner has failed to establish that
he is not liable for the year at issue for the accuracy-related
penalty under section 6662(a).8
To reflect the foregoing,
Decision will be entered for
respondent.
8We have found that petitioner is liable for the year at
issue for the accuracy-related penalty under sec. 6662(a) because
of negligence or disregard of rules or regulations under sec.
6662(b)(1). In light of that finding, we shall not address
respondent’s alternative argument that petitioner is liable for
the year at issue for the accuracy-related penalty under sec.
6662(a) because of a substantial understatement of income tax
under sec. 6662(b)(2).
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