Glory Allen - Page 10

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          secretary or executive assistant to the tribal president,                   
          respondent has met his section 7491(c) burden of production with            
          respect to the accuracy-related penalty at issue herein.                    
               Petitioner has not cited any legal authority that would                
          constitute substantial authority for her understatement of income           
          including self-employment income; petitioner did not disclose on            
          her 2001 individual Federal income tax return the $57,845 she in            
          2001 received from the tribe; and petitioner has not established            
          reasonable cause for her failure to pay income taxes on the                 
          $57,845 she received from the tribe and self-employment taxes on            
          the $33,295 she received for her work as secretary or executive             
          assistant to the tribal president.                                          
               Petitioner is liable for the section 6662(a) accuracy-                 
          related penalty.                                                            

                                                Decision will be entered              
                                           for respondent.                            


















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