- 8 -
Petitioner’s statement is an admission that he knew that his
claims were likely to be disallowed by the IRS. He disregarded
the applicable rules or regulations. He never consulted a tax
professional to determine whether his return position was
correct. We conclude that he knew that his claims were improper.
Therefore, the accuracy-related penalties for the years in issue
are sustained.
We have considered the arguments of the parties that were
not specifically addressed in this opinion. Those arguments are
either without merit or irrelevant to our decision.
To reflect the foregoing,
Decision will be entered
under Rule 155.
Page: Previous 1 2 3 4 5 6 7 8
Last modified: May 25, 2011