Deborah Joyce Windisch - Page 20

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          Sec. 6664(c)(1).  The decision as to whether the taxpayer acted             
          with reasonable cause and in good faith depends upon all                    
          pertinent facts and circumstances.  Sec. 1.6664-4(b)(1), Income             
          Tax Regs.  Generally, the most important factor is the extent of            
          the taxpayer's efforts to assess the proper tax liability.  Id.             
          A taxpayer must establish error in the determination that he or             
          she is liable for the penalty provided by section 6662(a).  Rule            
          142(a); Estate of Monroe v. Commissioner, 104 T.C. 352, 366                 
          (1995).                                                                     
               On brief, petitioner contends that she believed in good                
          faith that the expenses that she claimed were allowable.  Good              
          faith on the part of a taxpayer, however, does not always negate            
          negligence.  Taxpayers are required to take reasonable steps to             
          determine the law and to comply with it.  Niedringhaus v.                   
          Commissioner, 99 T.C. 202, 222 (1992).  In the instant case,                
          petitioner has not shown that her claimed deductions for expenses           
          were made with any significant regard to whether they were                  
          personal in nature, and the record supports the inference that              
          petitioner's photography activity was used to deduct personal               
          expenses.  We do not consider petitioner to have acted reasonably           
          with respect to the deduction of those expenses claimed for her             
          photography activity.  Moreover, petitioner failed to investigate           
          the qualifications of any of the persons owning or operating                
          United Sovereigns or of Mr. Webber before enlisting them to                 
          prepare her tax returns for the years in issue.  Based on our               




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