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utilities in respect of the rental portion of the Duplex.
Accordingly, applying the rationale of Cohan v. Commissioner, 39
F.2d at 544, and using our best judgment in the absence of
documentary evidence, we conclude that petitioner is entitled to
a deduction for utilities in the amount of $600.
Issue (9): Accuracy-related Penalty
Section 6662(a) and (b)(1) provides that if any portion of
an underpayment of tax is attributable to negligence or disregard
of rules or regulations, then there shall be added to the tax an
amount equal to 20 percent of the amount of the underpayment that
is so attributable. The term "negligence" includes any failure
to make a reasonable attempt to comply with the statute, and the
term "disregard" includes any careless, reckless, or intentional
disregard. Sec. 6662(c).
By virtue of section 6664(c)(1), the accuracy-related
penalty is not imposed with respect to any portion of an
underpayment if it is shown that there was a reasonable cause for
such portion and that the taxpayer acted in good faith with
respect to such portion. Whether a taxpayer acted in good faith
depends upon the pertinent facts and circumstances. Estate of
Monroe v. Commissioner, 104 T.C. 352, 366 (1995), revd. in part
on another ground and remanded 124 F.3d 699 (5th Cir. 1977); sec.
1.6664-4(b)(1), Income Tax Regs. The most important factor is
the extent of the taxpayer's effort to assess his or her proper
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