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entitled to such loss. Petitioner also filed as a head of
household for 1999 and 2000 when he was married to Mrs. Eastman-
Kent. Petitioner has not shown that he acted in good faith in
claiming these amounts. Respondent has met his burden of
production under section 7491(c). We conclude that petitioner’s
actions were not those of a reasonable and prudent person under
the circumstances. Thus, we sustain respondent on this
adjustment.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011