Gary Benton Logsdon and Karen Ruth Logsdon - Page 16

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          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's                   




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