- 16 - the issue as to the taxability of Johnston Island wages. We do not regard petitioner’s treatment on his 2000 individual Federal income tax return of his Johnston Island wages as negligent. We turn to the question of whether petitioner’s tax return treatment of his Johnston Island wages constituted a substantial understatement giving rise to the accuracy-related penalty. The grounds on which a substantial understatement may be reduced include tax treatments that are based on adequate disclosure and a reasonable basis. Sec. 6662(d)(2)(B)(ii). The disclosure made on petitioner’s 2000 Federal income tax return, as reflected on petitioner’s retained copy of such return, constitutes adequate disclosure for purposes of section 6662(d)(2)(B)(ii). Respondent provides no explanation for the incomplete nature of respondent’s printout of petitioner’s 2000 individual Federal income tax return. In deciding this disclosure issue, particularly in light of respondent’s burden of production on this penalty, we believe it appropriate to rely on the information reflected on petitioner’s retained copy of his 2000 individual Federal income tax return. On the facts of this case, the disclosure issue is resolved in favor of petitioner. With regard to reasonable basis, we incorporate our discussion above and conclude that petitioner, on his 2000 individual Federal income tax return, had a reasonable basis forPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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