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the tax return less the amount of tax shown in the tax return,
see sec. 6662(d)(2)(A), and is substantial in the case of an in-
dividual if it exceeds the greater of 10 percent of the tax
required to be shown or $5,000, see sec. 6662(d)(1)(A). The
amount of the understatement is reduced to the extent that it is
attributable to an item for which there was substantial author-
ity. See sec. 6662(d)(2)(B)(i).6
The accuracy-related penalty under section 6662(a) does not
apply to any portion of an underpayment if it is shown that there
was reasonable cause for such portion and that the taxpayer acted
in good faith. See 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. See
sec. 1.6664-4(b)(1), Income Tax Regs. The most important factor
is the extent of the taxpayer's efforts to assess his or her
proper tax liability. See id. Reliance on the advice of a
professional, such as an accountant, does not necessarily dem-
onstrate reasonable cause and good faith unless, under all the
circumstances, such reliance was reasonable and the taxpayer
acted in good faith. See id. In the case of claimed reliance on
the accountant who prepared the taxpayer's tax return, the
6The amount of the understatement also is reduced to the
extent that it is attributable to an item that was adequately
disclosed in the tax return and was treated by the taxpayer in a
manner having a reasonable basis. See sec. 6662(d)(2)(B)(ii).
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