- 10 - rules and regulations, or a substantial understatement of tax. An understatement of tax is substantial if it exceeds either 10 percent of the tax required to be shown on the return, or $5,000. Sec. 6662(d)(1)(A). The above accuracy-related penalty, however, is not imposed with respect to any portion of a taxpayer’s understatement of tax for which the taxpayer acted with reasonable cause and in good faith. Sec. 6664(c)(1). In our discretion, and based on the facts before us, we conclude that petitioners had reasonable cause in treating petitioner’s airplane activity as a for profit activity. Petitioners are not liable for the accuracy-related penalties determined by respondent under section 6662 with respect to the deficiencies at issue herein. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011