J. Brent Haymond and Janis S. Haymond - Page 10

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          Harchester Realty Corp. v. Commissioner, supra; cf. Vaira v.                
          Commissioner, supra (unpaid appraisal fees); Landreth v.                    
          Commissioner, T.C. Memo. 1985-413, affd. in part, revd. in part             
          and remanded 859 F.2d 643 (9th Cir. 1988) (unpaid legal fees).              


          Accuracy-Related Penalty                                                    
               Section 6662 imposes an accuracy-related penalty of 20                 
          percent of the portion of the underpayment of tax attributable to           
          any substantial understatement of income tax.  Sec. 6662(a) and             
          (b)(2).  There is no question that the understatement of tax                
          involved herein is substantial under section 6662(d)(1)(A).                 
               The accuracy-related penalty will not be imposed with                  
          respect to any portion of an 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.  Sec.            
          6664(c).  The determination of whether a taxpayer acted with                
          reasonable cause and in good faith depends upon the 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                  
          determine the taxpayer's proper tax liability.  Id.                         
               Generally, the taxpayer cannot avoid the duty of filing                
          accurate returns by placing responsibility on a tax return                  
          preparer.  Metra Chem Corp. v. Commissioner, 88 T.C. 654, 662               
          (1987).  Reliance on the advice of a professional does not                  





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