- 83 - case of an individual 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 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, and that the taxpayer acted in good faith with respect to, such portion. See sec. 6664(c)(1). Petitioners introduced no evidence and advance no conten- tions with respect to the accuracy-related penalty under section 6662(a). On the record before us, we find that petitioners have failed to show that they were not negligent and did not disregard rules or regulations within the meaning of section 6662(b)(1), or otherwise did what a reasonable person would do, with respect to any portion of the underpayment for 1995. On that record, we further find that petitioners have failed to show that they acted with reasonable cause and in good faith with respect to any portion of the underpayment for that year.40 See sec. 6664(c). Based on our examination of the entire record before us, we find that petitioners have failed to establish any error in respondent’s determination that they are liable for the year at issue for the accuracy-related penalty under section 6662(a). 40We also find on the record before us that there is a substantial understatement of tax under sec. 6662(b)(2). Peti- tioners showed no tax in petitioners’ 1995 joint return. The tax required to be shown in that return, as calculated by respondent in the notice, is $315,478, and we have sustained all of respon- dent’s determinations in the notice.Page: Previous 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 Next
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