- 17 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
Last modified: May 25, 2011