Frederick Douglas Abdullah - Page 18

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          As a defense to the penalty, petitioner bears the burden of                 
          proving that he acted with reasonable cause and in good faith.              
          See sec. 6664(c)(1); see also Higbee v. Commissioner, supra; sec.           
          1.6664-4(b)(1), Income Tax Regs.                                            
               Respondent satisfied his burden of production under section            
          7491(a)(1) because the record shows that petitioner substantially           
          understated his income tax for the year in issue.  See sec.                 
          6662(d)(1)(A)(ii); Higbee v. Commissioner, supra at 442.                    
          Accordingly, petitioner bears the burden of proving that the                
          accuracy-related penalty should not be imposed with respect to              
          any portion of the understatement for which he acted with                   
          reasonable cause and in good faith.  See sec. 6664(c)(1); Higbee            
          v. Commissioner, supra at 446.                                              
               A review of this record reflects that petitioner claimed               
          substantial deductions for which he apparently maintained no                
          records.  Further, some of the claimed deductions, like bad                 
          debts, which petitioner testified was personal interest, are                
          clearly nondeductible personal items.  Based on this entire                 
          record, we conclude that petitioner is liable for the penalty               
          under section 6662(a).                                                      
               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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