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Petitioner contends that he was unable to substantiate the
losses because Patrick refused to provide the businesses’
records. On August 16, 2002, the Superior Court of California,
County of Orange, issued an order requiring Patrick to provide
petitioner with the business records. Patrick did not comply
with the California Court’s order. On February 26, 2007, Patrick
evaded service of a subpoena for the 1998 records and did not
provide petitioner with access to such records. Petitioner has
earnestly and diligently attempted to obtain the requisite
documentation. Thus, he has demonstrated reasonable cause for
his failure to substantiate the losses and has acted in good
faith. Accordingly, petitioner is not liable for the section
6662(a) accuracy-related penalty.
Contentions we have not addressed are irrelevant, moot, or
meritless.
To reflect the foregoing,
Decision will be entered
for respondent as to the
deficiency; decision will be
entered for petitioner as to
the accuracy-related penalty.
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Last modified: November 10, 2007