Barry John and Deborah Lee Houston Mangels - Page 10




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          accuracy-related penalty is equal to 20 percent of any portion of           
          an underpayment of tax required to be shown on the return that is           
          attributable to, among other choices, any substantial                       
          understatement of income tax.  Sec. 6662(a) and (b)(2).  A                  
          taxpayer has a substantial understatement of income tax if the              
          amount of the understatement exceeds the greater of either 10               
          percent of the tax required to be shown on the return for the               
          taxable year or $5,000.  Sec. 6662(d)(1)(A).                                
               The penalties provided for in section 6662 are not imposed             
          on any portion of an underpayment if it is shown that there was             
          reasonable cause for such portion and the taxpayer acted in good            
          faith with respect to that portion.  Sec. 6664(c)(1); sec.                  
          1.6664-4(b), Income Tax Regs.  Whether the taxpayer has acted               
          with reasonable cause and in good faith is determined by relevant           
          facts and circumstances, including the taxpayer’s own efforts to            
          assess his proper tax liability.  Sec. 6664(c); Stubblefield v.             
          Commissioner, T.C. Memo. 1996-537.                                          
               Petitioners do not dispute adjustments in the notice of                
          deficiency including omitted wage income of $144, omitted                   
          interest income of $15, and omitted cancellation of debt income             
          of $1,141.  Also, at trial petitioners conceded omitted income              
          received from Sal Parziale or JWH of $11,471.  Further, we                  
          concluded that petitioner received an additional $8,000 from this           
          source.  Petitioners did not provide any explanation as to the              
          failure to report these items of income.  We conclude that                  




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