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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