Cathy M. and Randy L. Crosson - Page 10

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          forward with sufficient evidence indicating that it is                      
          appropriate to impose” the accuracy-related penalty.  Id.                   
          Respondent contends that he has met that burden.  The record                
          reveals that petitioners have failed to comply with the                     
          requirements of the Internal Revenue Code, including their                  
          failure to maintain adequate books and records and/or to                    
          substantiate the claimed business deductions.                               
               A taxpayer may avoid the accuracy-related penalty by showing           
          that (1) there was reasonable cause for the underpayment, and (2)           
          he acted in good faith with respect to such underpayment.  Sec.             
          6664(c)(1).  Whether a taxpayer acted with reasonable cause and             
          in good faith is determined by the relevant facts and                       
          circumstances, and most importantly, the extent to which he                 
          attempted to assess his proper tax liability.  Sec. 1.6664-                 
          4(b)(1), Income Tax Regs.                                                   
               Petitioners have offered no evidence to show that they kept            
          adequate books or can substantiate their claimed deductions.                
          Moreover, petitioners have not shown that there was reasonable              
          cause for the underreporting of their 1999 tax liability.                   
          Accordingly, petitioners are liable for the section 6662(a)                 
          accuracy-related penalty.                                                   
               To reflect the foregoing,                                              
                                             Decision will be entered                 
                                        for respondent.                               






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