Carol Anderson - Page 10

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          one of which is negligence or disregard of rules or regulations.            
          Sec. 6662(b)(1).  Respondent determined that petitioner is liable           
          for the accuracy-related penalty imposed by section 6662(a) for             
          her underpayments of taxes in 1992 and 1993, and that such                  
          underpayments were due to negligence or disregard of rules or               
          regulations.  "Negligence" includes a failure to make a                     
          reasonable attempt to comply with the provisions of the Internal            
          Revenue laws or to exercise ordinary and reasonable care in the             
          preparation of a tax return.  Sec. 6662(c); sec. 1.6662-3(b)(1),            
          Income Tax Regs.  "Disregard" includes any careless, reckless, or           
          intentional disregard of rules or regulations.  Sec. 6662(c);               
          sec. 1.6662-3(b)(2), Income Tax Regs.                                       
               Section 6664(c)(1), however, provides that the penalty under           
          section 6662(a) shall not apply to any portion of an                        
          underpayment, if it is shown that there was reasonable cause for            
          the taxpayer's position with respect to that portion and that the           
          taxpayer acted in good faith with respect to that portion.  The             
          determination of whether a taxpayer acted with reasonable cause             
          and in good faith is made on a case-by-case basis, taking into              
          account all the pertinent facts and circumstances.  Sec.                    
          1.6664-4(b)(1), Income Tax Regs.  The most important factor is              
          the extent of the taxpayer's effort to assess her proper tax                
          liability for the year.  Id.                                                
               Based on the record, we find that petitioner has not proved            
          that her underpayments were due to reasonable cause or that she             




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