Benjamin C. Kent - Page 15

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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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