Matthew P. Brown - Page 11

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          failed to show that he acted with reasonable cause or in good               
          faith.  Accordingly, we hold petitioner is liable for the                   
          accuracy-related penalties.                                                 
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             under Rule 155.                          
                                                                                     






























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