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Respondent has satisfied his burden of production under
section 7491(c) by establishing that petitioner received the
income items that he failed to report. Petitioner does not
dispute receiving the payments and offered no reasonable cause for
his failure to report the items.
The Court holds that petitioner is liable for the accuracy-
related penalty under section 6662(a).
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011