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Commissioner, T.C. Memo. 1998-163, affd. without published
opinion 188 F.3d 514 (9th Cir. 1999).
Because the underpayment is attributable to negligence of
petitioner and he has not proven that he had reasonable cause for
the underpayment and acted in good faith regarding the
underpayment, we sustain respondent’s determination that
petitioner is liable for the accuracy-related penalty.
To reflect the foregoing,
Decision will be entered
for respondent.
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