Karen Ann Keegan - Page 17

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            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.                                 

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Last modified: May 25, 2011