United States Sixth Circuit

A decision finding petitioner liable for a negligence penalty for a taxable year due to improper calculation of petitioner's tax liability is affirmed where there was no clear error in a determination that petitioner failed to carry his burden of proving his reasonable care.

Appellate Information

• Decided 02/28/2006
• Published 02/28/2006

Judges

• Before:  MERRITT, MARTIN, and GILMAN, Circuit Judges.

Court

• United States Sixth Circuit

Counsel

• For Appellees:
  
• ARGUED:  Terri A. Merriam, Pearson-Merriam, Seattle, Washington, for Appellant.  Annette Wietecha, United States Department of Justice, Washington, D.C., for Appellee.   ON BRIEF:  Terri A. Merriam, Wendy S. Pearson, Pearson-Merriam, Seattle, Washington, for Appellant.   Annette Wietecha, Richard Farber, United States Department of Justice, Washington, D.C., for Appellee.