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determination of whether a taxpayer acted with reasonable cause
and in good faith is made on a case-by-case basis, taking into
account all the pertinent facts and 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.
Petitioner failed both to keep adequate books and records
reflecting income of his businesses and to properly substantiate
the numerous and varied items reported on his return. See sec.
6662(c); sec. 1.6662-3(b)(1), Income Tax Regs. We hold that the
record supports respondent’s determination of negligence in this
case, and nothing in the record indicates petitioner acted with
reasonable cause and in good faith.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011