- 7 -
did not address on brief) the remaining amount of underreported
income.
The typical indicia of an intent to evade tax are not
present. Petitioner maintained adequate records, made all
pertinent information available to the Internal Revenue Service,
and cooperated with the Internal Revenue Service’s investigation.
In short, petitioner understated his income, but respondent has
not established that petitioner intended to evade tax.
Accordingly, we reject respondent’s determinations.
Contentions we have not addressed are irrelevant, moot, or
meritless.
To reflect the foregoing,
Decisions will be entered
for petitioner.
Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011