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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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Last modified: May 25, 2011