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with reasonable cause and in good faith depends upon all
pertinent facts and circumstances. Sec. 1.6664-4(b)(1), Income
Tax Regs. The most important factor is the extent of the
taxpayer's efforts to assess the proper tax liability. Id.
Circumstances that may indicate reasonable cause and good faith
include an honest misunderstanding of fact or law that is
reasonable in light of the experience, knowledge, and education
of the taxpayer. Id. Petitioners must establish error in
respondent's determination that they are liable for the penalty
provided by section 6662(a). Rule 142(a); Estate of Monroe v.
Commissioner, 104 T.C. 352, 366 (1995).
On the basis of the record in the instant case, we conclude
that petitioners had reasonable cause and acted in good faith.
We are satisfied by the record in the instant case that
petitioners had substantiation for most if not all of their
deductions they filed their return. Mr. Brown testified that he
gave all receipts relating to his tree stumping business to Mrs.
Brown, who stored the books and records of the business in their
home. Additionally, petitioners testified that, at Mrs. Brown's
first meeting with Ms. Daniels, petitioners had substantiation
for all of the deductions that they claimed on their return. We
note that petitioners' testimony was uncontroverted by
respondent. At trial, respondent asked Ms. Daniels whether,
during the first meeting with Mrs. Brown, she looked at all of
the documents that Mrs. Brown presented at that time. Ms.
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