Ahsan Mohiuddin - Page 28

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               Section 6664(c)(1) provides that the penalty should not be             
          imposed on any portion of an underpayment if the taxpayer shows             
          reasonable cause for such portion of the underpayment and that              
          the taxpayer acted in good faith with respect to such portion.              
          Reliance on the advice of a professional such as an accountant              
          may constitute a showing of reasonable cause if, under all the              
          circumstances, such reliance was reasonable and the taxpayer                
          acted in good faith.  Sec. 1.6661-6(b), Income Tax Regs.                    
               Petitioner has failed to show that he was not negligent.               
          There is no evidence that petitioner made a reasonable attempt to           
          comply with the statutes or regulations in filing his Federal               
          income tax returns for any of the years at issue.  Had petitioner           
          consulted either the relevant statutes or a competent tax adviser           
          he would have discovered that many of the deductions he claimed             
          were not proper.  It is clear from the facts in this case, and              
          from petitioner's brief, that petitioner claimed these deductions           
          and expenses without regard to the applicable law.  Therefore, we           
          sustain the accuracy-related penalty for each year as determined            
          by respondent.                                                              
                                                       Decisions will be              
                                             entered under Rule 155.                  











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