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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. See 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. See id.
Based on the record, we find that petitioners have not
proved that their underpayments attributable to the disallowed
charitable contribution deductions were due to reasonable cause
or that they acted in good faith. We hold that petitioners are
liable for the section 6662(a) accuracy-related penalties as
determined by respondent.
To reflect the foregoing,
Decision will be entered
under Rule 155.5
5 We lack jurisdiction over any increased deficiencies
which may result from our holdings on the issues in this case
because respondent has not asserted any claim for increased
deficiencies. See sec. 6214(a).
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