Alec Jeffrey Megibow - Page 32

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          communication and exchange of pertinent information.  Conversely,           
          the record is devoid of any evidence reflecting offers of                   
          settlement or payment, nor would such offers bear in any event on           
          whether petitioner was negligent at the point in time when he               
          filed his Federal income tax return and underpaid his taxes.  On            
          these facts, petitioner’s intimations of a denial of due process            
          are not well taken.                                                         
               Finally, petitioner is entitled to minimize income taxes               
          only to the extent consistent with law.  See United States v.               
          Cumberland Pub. Serv. Co., 338 U.S. 451, 454-456 (1950).  He                
          clearly overstepped that boundary here and has not shown a                  
          reasonable basis for doing so.  The Court sustains respondent’s             
          imposition of the section 6662 penalty.                                     
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             for respondent.                          


















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