Karl T. and Kathleen S. Harvey - Page 8




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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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