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The Court concludes that respondent has met his burden of
production and that petitioner failed to persuade us that the
determination was in error. The Court finds that petitioner was
negligent because he failed to make a reasonable attempt to
ascertain the correctness of his deduction since he merely
testified, without more, that he thought he should be compensated
for his pro se work in the courts: “somebody has to pay this.
It is damage. It is a casualty.” Because petitioner failed to
make a reasonable attempt to ascertain the correctness of his
deduction, he cannot establish a reasonable cause and good faith
defense. Accordingly, respondent’s determination is sustained.
To reflect the foregoing,
Decision will be entered for
respondent in docket No. 4480-06S,
and decision will be entered under
Rule 155 in docket No. 4481-06S.
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Last modified: November 10, 2007