- -28 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.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Last modified: May 25, 2011