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Here, we conclude that respondent has met his burden of
production with respect to the accuracy-related penalty.
Petitioner’s amended return for 2003 shows total tax due of zero.
Thus, the deficiency in this case, which is greater than $5,000,
is a substantial understatement within the meaning of section
6662(d). In addition, the deficiency in this case is
attributable to negligence as defined in section 6662(c), as
petitioner has failed to make any reasonable attempt to comply
with the provisions of the Internal Revenue Code. In that
petitioner has introduced no evidence to support a finding of
reasonable cause, we sustain respondent’s determination as to the
accuracy-related penalty.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011