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PURSUANT TO INTERNAL REVENUE CODESECTION 7463(b),THIS OPINION MAY NOTBE TREATED AS PRECEDENT FOR ANYOTHER CASE.

Hereinafter, all section references are to the InternalRevenue Code in effect for the years at issue. All Rule refer-ences are to the Tax Court Rules of Practice and Procedure.T.C. Summary Opinion 2010-78UNITED STATES TAX COURTDAVID CAMERON PARKER, Petitioner v.COMMISSIONER OF INTERNAL REVENUE, RespondentDocket No. 26478-08S. Filed June 21, 2010.David Cameron Parker, pro se.Anne W. Bryson, for respondent.CHIECHI, Judge: This case was heard pursuant to the provi-sions of section 7463 of the Internal Revenue Code in effect whenthe petition was filed.

Pursuant to section 7463(b), the deci-sion to be entered is not reviewable by any other court, and thisopinion shall not be treated as precedent for any other case.

- 2 -Respondent determined that petitioner is liable for histaxable years 2005 and 2006 for accuracy-related penalties undersection 6662(a) of $2,435.40 and $2,655.40, respectively. Wemust decide whether petitioner is liable for those penalties. Wehold that he is.BackgroundSome of the facts have been stipulated and are so found.Petitioner resided in Washington, D.C., at the time he filedthe petition in this case.At a time not disclosed by the record before 2005, the firstyear at issue, petitioner, who has a bachelor of science degreein business administration, worked for 17 years for the FederalDeposit Insurance Corporation (FDIC).After he stopped working for the FDIC, petitioner worked asan independent contractor for the U.S. Agency for InternationalDevelopment (AID) and the Office of Technical Assistance of theU.S. Department of the Treasury (Treasury’s Office of TechnicalAssistance). His responsibilities in that work included provid-ing advice regarding problem bank resolution and deposit insur-ance.As of 2005, petitioner had approximately 20 years of experi-ence in problem bank resolution and deposit insurance and viewedhimself as an expert in those areas. Having worked extensivelyin the areas of problem bank resolution and deposit insurance,