- 24 - 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 a taxpayer acted with reasonable cause and in good faith depends on the pertinent facts and circumstances, including the taxpayer’s efforts to assess his or her proper tax liability, the knowledge and experience of the taxpayer, and the reliance on the advice of a professional, such as an accountant. See sec. 1.6664-4(b)(1), Income Tax Regs. Based on our examination of the entire record before us, we find that Mr. Mitic, who listed his occupation in both the 1993 and 1994 joint returns as “Accountant”, has failed to establish that petitioners are not liable for the years at issue for the accuracy-related penalties under section 6662(a).10 We have considered all of the arguments of Mr. Mitic that are not discussed herein, and we find them to be without merit and/or irrelevant. To reflect the foregoing and the concessions of the parties,11 10The amount of the accuracy-related penalty for which petitioners are liable for each of the years at issue shall be determined in the Rule 155 computations by taking into account the concessions of the parties in the first stipulation of settled issues filed in this case. 11After Rule 155 computations have been submitted, we shall grant respondent’s motion and enter a decision with respect to (continued...)Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
Last modified: May 25, 2011