- 10 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011