Roydell Campbell - Page 8




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          respect to such underpayment.  See sec. 6664(c).  Whether the               
          taxpayer acted with reasonable cause and in good faith is                   
          determined by the relevant facts and circumstances.  The most               
          important factor is the extent of the taxpayer’s effort to assess           
          the proper tax liability.  See Stubblefield v. Commissioner, T.C.           
          Memo. 1996-537; sec. 1.6664-4(b)(1), Income Tax Regs.  Section              
          1.6664-4(b)(1), Income Tax Regs., specifically provides:                    
          “Circumstances that may indicate reasonable cause and good faith            
          include an honest misunderstanding of fact or law that is                   
          reasonable in light of all of the facts and circumstances,                  
          including the experience, knowledge, and education of the                   
          taxpayer.”  See Neely v. Commissioner, 85 T.C. 934 (1985).                  
               A taxpayer is generally charged with knowledge of the law.             
          See Niedringhaus v. Commissioner, 99 T.C. 202, 222 (1992).                  
          Ignorance of the law is not always a defense to the imposition of           
          section 6662(a).  A taxpayer must take reasonable steps to                  
          determine the law and apply it.  See id.                                    
               It is the taxpayer’s responsibility to establish that he or            
          she is not liable for the accuracy-related penalty imposed by               
          section 6662(a).  See Rule 142(a); Tweeddale v. Commissioner, 92            
          T.C. 501, 505 (1989).                                                       
               Petitioner argues that he relied on the 1997 version of IRS            
          Publication 17 (Tax Guide for Individuals).  The section                    
          regarding loans is as follows:                                              






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