- 32 -
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.
Page: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Last modified: May 25, 2011