-14-
understatement for each of the years at issue was due to
reasonable cause and that he acted in good faith.10
Accordingly, we sustain respondent’s determination that
petitioner is liable for the accuracy-related penalty under
section 6662(b)(2) for each of the years at issue.
We have considered all remaining arguments the parties made
and, to the extent not addressed, we find them to be irrelevant,
moot, or meritless.
To reflect the foregoing,
Decision will be entered
for respondent.
10Petitioner argues that the complexity of issues in this
case gave him reasonable cause for his substantial
understatements. See Dillin v. Commissioner, 56 T.C. 228, 248
(1971). We disagree. There is no uncertainty as to petitioner’s
legal obligation here. See, e.g., Pessin v. Commissioner, 59
T.C. 473, 489 (1972); Rosanova v. Commissioner, T.C. Memo. 1985-
306; Grant v. Commissioner, T.C. Memo. 1980-242.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14
Last modified: May 25, 2011