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(c) Reasonable Cause Exception.--
(1) In general.--No penalty shall be imposed
under this part with respect to any portion of an
underpayment if it is shown that there was a
reasonable cause for such portion and that the
taxpayer acted in good faith with respect to such
portion.
So far as the record reflects, petitioner's deduction of alimony
had no factual basis. Although he did substantiate payments
toward support of his children, he has failed to prove that he
made a reasonable effort to determine whether those payments
qualified him for dependency exemptions for the years in issue or
for head of household status for 1993. He has failed to prove
that he is not liable for the penalties determined by respondent.
Decision will be entered
for respondent.
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Last modified: May 25, 2011