Jerry Howard-Crowley - Page 17

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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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