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difficulties, in the Court’s view, did not constitute reasonable
cause for an understatement of Federal income tax within the
meaning of section 6664(c). Income was knowingly omitted from
petitioner’s return, and he did not include any information with
the return that would have alerted respondent that the omitted
income and the tax due thereon would be reported later when the
necessary information would be available. The record, therefore,
reflects that petitioner failed to make a sufficient effort to
ascertain his proper tax liability for 2002. Accordingly,
respondent is sustained on the imposition of the accuracy-related
penalty under section 6662(a).
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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Last modified: May 25, 2011