- 17 - penalty does not apply to any portion of an underpayment for which there was reasonable cause and with respect to which the taxpayer acted in good faith. Sec. 6664(c). Generally, taxpayers bear the burden of proving that they are not liable for the accuracy-related penalty imposed by section 6662(a). Rule 142(a); Tweeddale v. Commissioner, 92 T.C. 501, 505 (1989). Petitioner has failed to offer any evidence to suggest that she acted with reasonable cause and good faith with respect to the issues discussed herein. Petitioner has failed in her burden of proving that she is not liable for the accuracy-related penalty. We, therefore, sustain respondent's determination that petitioner is liable for the accuracy-related penalty under section 6662(a) for the taxable years 1994 and 1995. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
Last modified: May 25, 2011