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The accuracy-related penalties will apply unless petitioners
demonstrate that there was reasonable cause for the under-
payments and that they acted in good faith with respect to the
underpayments. Sec. 6664(c). Whether a taxpayer acted with
reasonable cause and good faith depends on the pertinent facts
and circumstances. McCallson v. Commissioner, T.C. Memo. 1993-
528; sec. 1.6664-4(b)(1), Income Tax Regs. Petitioners must show
that they were not negligent. Cluck v. Commissioner, 105 T.C.
324, 339 (1995).
Petitioners failed to produce any evidence to show that they
were not negligent for either of the years at issue. They have
failed to carry their burden of proof. We sustain respondent's
determination that they are liable for the accuracy-related
penalty for 1993 and 1994.
To reflect the foregoing,
Decision will be entered
for respondent.
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