Jane Crocker, F.K.A. Jane C. Jacobs, et al. - Page 20

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          of the underpayment attributable to negligence or disregard of              
          rules or regulations, any substantial understatement of income              
          tax, or any substantial valuation overstatement.  See sec.                  
          6662(b)(1)-(3).  The section 6662 accuracy-related penalty does             
          not apply with respect to any portion of an underpayment if                 
          reasonable cause exists for the underpayment and the taxpayer               
          acted in good faith with respect to such portion.  Sec.                     
          6664(c)(1).  The determination of whether the taxpayer acted with           
          reasonable cause and in good faith depends upon the pertinent               
          facts and circumstances.  Sec. 1.6664-4(b), Income Tax Regs.  The           
          most important factor in determining reasonable cause is the                
          extent of the taxpayer's effort to assess the proper tax                    
          liability.  Sec. 1.6664-4(b), Income Tax Regs.                              
               In our judgment, Jacobs acted with reasonable cause and in             
          good faith when he claimed the charitable contribution deduction            
          for his donation of the Redwood City Fox.  Accordingly, we hold             
          that he is not liable for the section 6662 accuracy-related                 
          penalties for 1989 and 1990.                                                
               To reflect the foregoing,                                              


                                             Decisions will be entered                
                                        under Rule 155.                               









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