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underpayment if it is shown that there was a reasonable cause for
such portion and that the taxpayer acted in good faith with
respect to such portion. Whether a taxpayer acted in good faith
depends upon the pertinent facts and circumstances. Estate of
Monroe v. Commissioner, 104 T.C. 352, 366 (1995); sec. 1.6664-
4(b)(1), Income Tax Regs. The most important factor is the
extent of the taxpayer's effort to assess his or her proper tax
liability. Beard v. Commissioner, T.C. Memo. 1995-41; sec.
1.6664-4(b)(1), Income Tax Regs.
The burden of proving that the accuracy-related penalty
should not be imposed rests with the taxpayer. Rule 142(a);
INDOPCO Inc. v. Commissioner, 503 U.S. 79, 84 (1992); Welch v.
Helvering, 290 U.S. 111, 115 (1933).
Petitioner contends that he is not liable for the accuracy-
related penalty because he maintained accurate records of his
income and because he accurately reported his income. We
disagree.
Insofar as petitioner's unreported interest income is
concerned, the record demonstrates that petitioner received
interest in the amount of $626.07 from Channelview Bank in
respect of his savings account with that institution. However,
on his 1991 income tax return, petitioner only reported $100 of
interest, an amount that appears to have been estimated and that
bears no relation to the amount of interest that was earned.
Thus, it cannot be said that petitioner maintained accurate
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