- 19 - Petitioner has failed to meet his burden of persuasion with respect to the accuracy-related penalties. Petitioner claimed substantial deductions for which he apparently maintained no records. At trial, petitioner admitted that some of the deductions on his Schedules C for 2001 and 2002 may have represented personal expenditures, including the costs of a family trip to Mexico and payments for insurance premiums on his personal automobiles. As noted supra, petitioner likely incurred several business expenditures during 2001 and 2002. However, petitioner has not produced any evidence establishing that he acted with reasonable cause and in good faith with respect to any portion of the understatements of tax on his 2001 and 2002 income tax returns. Therefore, to the extent that we uphold respondent’s determination of deficiencies for 2001 and 2002, we conclude that petitioner is liable for the section 6662(a) penalties. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20Last modified: November 10, 2007