- 11 - Although we find that petitioners’ underpayment attributable to the Florida tax certificate interest was due to reasonable cause, the portion of petitioners’ Social Security benefits required to be included in gross income is not affected by whether the tax certificate interest is exempt from taxation. Both taxable and tax-exempt interest are counted for purposes of the income thresholds that determine the taxability of Social Security benefits. See sec. 86(b)(2). Thus any misunderstanding of Mr. Penn’s with respect to the tax-exempt status of interest petitioners received on tax certificates should have had no impact on the computation of the amount of petitioners’ Social Security benefits subject to tax. Nothing else in the record suggests that there was reasonable cause for petitioners’ failure to include the appropriate amount of their Social Security benefits in income. Accordingly, we find that petitioners are subject to the accuracy-related penalty on the portion of their underpayment attributable to unreported Social Security benefits. Finally, in the absence of any evidence of reasonable cause, we find that petitioners are liable for the accuracy-related penalty on the portion of their underpayment attributable to unreported bank interest income of $701. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011