Roger G. and Lilianne J. G. Maki - Page 5

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               Therefore, we hold that one-half of petitioner's Social                
          Security disability benefits, in the amount of $3,150 is taxable            
          for the year in issue.  Sec. 86(a).  Petitioners failed to                  
          present any evidence contrary to respondent's position.  Rule               
          142(a).  Accordingly, respondent is sustained on this issue.                
               The final issue for decision is whether petitioners are                
          liable for the section 6662(a) accuracy-related penalty.  Section           
          6662(a) imposes a 20-percent penalty on the portion of an                   
          underpayment attributable to any one of various factors, one of             
          which is negligence.  Respondent determined that petitioners are            
          liable for the accuracy-related penalty imposed by section                  
          6662(a), and that the entire underpayment of tax was due to                 
          negligence.  "Negligence" includes a failure to make a reasonable           
          attempt to comply with the provisions of the Internal Revenue               
          laws or to exercise ordinary and reasonable care in the                     
          preparation of a tax return.  Sec. 6662(c); sec. 1.6662-3(b)(1),            
          Income Tax Regs.  "Disregard" includes any careless, reckless, or           
          intentional disregard of rules or regulations.  Sec. 6662(c);               
          sec. 1.6662-3(b)(2), Income Tax Regs.                                       
               However, section 6664(c)(1) provides that the penalty under            
          section 6662(a) shall not apply to any portion of an                        
          underpayment, if it is shown that there was reasonable cause for            
          the taxpayer's position with respect to that portion and that the           
          taxpayer acted in good faith with respect to that portion.  Sec.            
          6664(c)(1).  The determination of whether a taxpayer acted with             




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