Estate of Carolyn W. Holland, Deceased, Jack K. Holland, Lewis G. Holland, Sr., and Betty H. Kann, Executors - Page 62

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          if it is shown that there was a reasonable cause for such                   
          position and that the taxpayer acted in good faith with respect             
          to such position.                                                           
               Under section 1.6664-4(b)(1), Income Tax Regs., the most               
          important factor in determining whether a taxpayer has acted with           
          reasonable cause and good faith is the extent of the taxpayer's             
          effort to assess the taxpayer's proper tax liability.                       
          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.                                                       
               We have already found that the positions taken on the return           
          filed by Jack, an experienced attorney in tax matters, have no              
          support in fact or law.  Nor can we find that the positions taken           
          on the return are the result of an honest misunderstanding of               
          fact or law that is reasonable in light of the experience,                  
          knowledge and education of the taxpayer.  Thus, considering all             
          the facts and circumstances, we do not find that petitioner acted           
          with reasonable cause and in good faith.                                    
               Petitioner asserts in the alternative, that the accuracy-              
          related penalty should not be imposed because it disclosed its              
          positions on the return.                                                    
               No penalty under section 6662(b)(1) may be imposed on any              
          portion of an underpayment that is attributable to negligence if            






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