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brief has addressed only negligence or disregard of rules or
regulations as the basis for the penalty, and we shall do
likewise.
We conclude that respondent has met the section 7491(c)
burden of production with respect to the negligence penalty. The
evidence adduced in this case reveals that petitioner has failed
to keep adequate books and records and properly to substantiate
reported items. Petitioner, in turn, has not shown that he acted
with reasonable cause and in good faith as to the claimed items.
His argument on brief with regard to the penalties reads as
follows:
Petitioner has done everything he reasonably could be
expected to do to pay his taxes when due, tender
security for over 100% of the claimed “additions” to
taxes dreamed up by respondent under any theory, and
petitioner’s efforts at cooperation, offers of
settlement, coupled with tendered funds, have been
refracted or ignored at every turn, including those
within the context of these proceedings, such that the
history can be viewed ultimately as a denial of
petitioner’s procedural due process rights.
Petitioner is entitled to minimize his income taxes
under the Internal Revenue Code.
This picture is belied by the record in this case. Contrary
to petitioner’s suggestions of cooperation and forthcoming
behavior, his history before the Internal Revenue Service and
this Court is replete with instances where petitioner, or the
representative acting on his behalf, has delayed, ignored, or
otherwise hindered repeatedly offered opportunities for
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