Bradley D. Becnel - Page 11

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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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