22
Secs. 6662(d)(2)(b), 6664(c)(1). 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 proper tax
liability. Cf. Beard v. Commissioner, T.C. Memo. 1995-41; sec.
1.6664-4(b)(1), Income Tax Regs. Petitioners have not impressed
upon this Court that there was reasonable cause or basis for the
underpayment, or that they adequately sought to determine their
proper tax liability. We find in favor of respondent.
Decision will be entered
for respondent.
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