Nicholas A. and Marjorie E. Paleveda - Page 20

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          of an underpayment with respect to which it is shown that there             
          was a reasonable cause and that the taxpayer acted in good faith.           
          Sec. 6664(c)(1).  The decision as to whether the taxpayer acted             
          with reasonable cause and in good faith depends upon all                    
          pertinent facts and circumstances.  Sec. 1.6664-4(b)(1), Income             
          Tax Regs.  The most important factor is the extent of the                   
          taxpayer's efforts to assess the proper tax liability.  Id.                 
          Circumstances that may indicate reasonable cause and good faith             
          include an honest misunderstanding of fact or law that is                   
          reasonable in light of the experience, knowledge, and education             
          of the taxpayer.  Id.  Petitioners must establish error in                  
          respondent's determination that they are liable for the penalty             
          provided pursuant to section 6662(a).  Rule 142(a); Estate of               
          Monroe v. Commissioner, 104 T.C. 352, 366 (1995).                           
               As to the penalties determined by respondent in the notice             
          of deficiency, petitioners contend that they are not liable                 
          because, at the audit, they produced canceled checks in support             
          of their deductions.  Additionally, petitioners argue that                  
          respondent required evidence beyond petitioners' checks that, in            
          some cases, was impossible to produce.  Finally, petitioners                
          contend that there was no negligence and that they acted in good            
          faith.                                                                      
               We conclude that petitioners have not established error in             
          respondent's determination that they are liable for the section             
          6662(a) penalty.  The section 6662(a) penalty does not apply to             




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