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Code. The evidence petitioner did provide that shows certain
amounts of income that he received in the year in issue does not
correspond to the total amount reflected on his return. Nor does
the amount of income reported on his return correspond to the
Forms 1099-MISC which petitioner was issued. Despite being
involved in transactions resulting in bank deposits of over
$325,000, petitioner testified that “I also am mindful of the fact
that there’s probably a valid criticism that could be made of me
because I do not keep records that are precise, that can be added
up and totaled.” We sustain respondent’s determination with
respect to the section 6662(a) accuracy-related penalty, as
modified by respondent’s concession concerning the amount of
unreported income.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
under Rule 155.
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