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any portion 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). We conclude that the presentation
of canceled checks by petitioners at the audit, standing alone,
does not establish that there was reasonable cause for the
portion of the underpayment or that petitioners acted in good
faith with respect to that portion. Additionally, petitioners'
mere allegation that, in the instant case, they were not
negligent and that they acted in good faith does not meet the
requirements of section 6664(c). Petitioners have provided no
other evidence upon which a finding of reasonable cause and good
faith could be premised. Accordingly, we sustain respondent's
determination of a section 6662(a) penalty as to the deficiency
which is calculated in the Rule 155 computations that we order
below.
We have considered all of petitioners' remaining arguments
and find them to be without merit.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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