- 17 - 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 proved that their underpayments were due to reasonable cause and that they acted in good faith. Petitioners were able to substantiate most of the expenses claimed on their returns and disallowed by respondent. We hold that petitioners are not liable for the section 6662(a) accuracy-related penalties for 1993 and 1994. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
Last modified: May 25, 2011