- 13 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14Last modified: November 10, 2007