R. Edwin Brown and Winsome S. Brown - Page 17

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          underpayment if it is shown that there was reasonable cause for             
          such portion of the underpayment and that the taxpayers acted in            
          good faith with respect to such portion.  Sec. 6664(c)(1).  The             
          determination of whether the taxpayers acted with reasonable                
          cause and in good faith depends upon the pertinent facts and                
          circumstances.  Sec. 1.6664-4(b)(1), Income Tax Regs.  The most             
          important factor is the extent of the taxpayers’ effort to assess           
          their proper tax liability for the taxable year.  Id.                       
               After carefully examining the record, we find no basis on              
          which we can find that petitioners had substantial authority,               
          that they adequately disclosed the relevant facts concerning the            
          items on their tax return, or that they acted with reasonable               
          cause and in good faith with respect to any portion of the                  
          understatement determined by respondent.  We have considered all            
          of petitioners’ arguments on this point and find them to be                 
          without merit.  On the instant record, we sustain respondent’s              
          determination that petitioners are liable for the accuracy-                 
          related penalty with respect to their entire underpayment of tax            
          for 1990.                                                                   
               To reflect the foregoing, and to take into account                     
          concessions made,                                                           
                                             An appropriate order will be             
                                        issued and decision will be                   
                                        entered under Rule 155.                       

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