- 10 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11
Last modified: May 25, 2011