Tommy L. and Patricia A. Hobson - Page 7

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          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.  Although we found that petitioners' failure             
          to timely file their 1990 return was due to reasonable cause, we            
          find that the record fails to establish that petitioners acted              
          with reasonable cause and in good faith in assessing whether                
          petitioner's distribution from her profit sharing plan was                  
          taxable.  Petitioners offered no evidence that they made a good             
          faith effort to assess their proper tax liability.  Based on this           
          record, we conclude that petitioners are liable for the section             
          6662 accuracy-related penalty as determined by respondent.                  
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             under Rule 155.                          



















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