- 17 - underpayment and that the taxpayer acted in good faith with respect to that portion. The determination of whether a taxpayer acted with reasonable cause and in good faith is made on a case- by-case basis, taking into account all the pertinent facts and circumstances. Sec. 1.6664-4(b)(1), Income Tax Regs. The most important factor is the extent of the taxpayer's effort to assess his proper tax liability for the year. Id. Based on the record, we find that Michael and Bonnie have not proved that their underpayments were due to reasonable cause or that they acted in good faith. We hold that Michael and Bonnie are liable for the section 6662(a) accuracy-related penalty for 1992, 1993, and 1994. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
Last modified: May 25, 2011