Tae M. Kim and Young J. Kim - Page 17




                                       - 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.                          



























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