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if it is shown that there was reasonable cause for the taxpayer's
position with respect to that portion 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 petitioners' underpayments
for 1992, 1993, and 1994 were not due to reasonable cause and
that they did not act in good faith. Accordingly, we hold that
petitioners are liable for the section 6662(a) accuracy-related
penalties for the taxable years in issue as determined by
respondent.
To reflect the foregoing,
Decision will be entered
for respondent.
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