- 16 - establish that they adequately disclosed the balance of the lump- sum credit. The accuracy-related penalty pursuant to section 6662(b)(2) does not apply to any portion of an underpayment if it is shown that there was reasonable cause for that portion of the underpayment and that the taxpayers acted in good faith with respect to such portion. Sec. 6664(c)(1). The determination of whether petitioners acted with reasonable cause and in good faith depends upon the pertinent facts and circumstances. Sec. 1.6664- 4(b)(1), Income Tax Regs. The most important factor is the extent of the taxpayers' effort to assess their proper tax liability for the taxable year. Id. After carefully examining the record, we find no basis on which we can conclude that petitioners acted with reasonable cause and in good faith with respect to any portion of the understatement determined by respondent. By their own admission, petitioners acknowledge that Mr. Logsdon is a "professional accountant and is well versed in tax reporting procedures," yet they do not present any evidence of their effort to assess their proper tax liability. Petitioners have failed to prove that they had substantial authority, that they adequately disclosed the relevant facts concerning the lump-sum credit, or that they acted with reasonable cause and in good faith with respect to any portion of the understatement. Because petitioners' understatement for the 1991 taxable year is substantial, we sustain respondent'sPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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