- 16 - important factor is the extent of the taxpayer’s effort to assess his proper tax liability for the year. Id. Petitioners made a substantial understatement of tax on their 1996 return. They have failed to produce books and records or to otherwise show the method used to arrive at the amounts of the deductions and income which were reported. Based on the record before us, we find petitioners have not established that they had substantial authority or a reasonable basis for the items in question. Nor have they established that there was reasonable cause for the underpayment or that they acted in good faith with respect to the underpayment. Consequently, we sustain respondent’s determination that petitioners are liable for the section 6662(a) accuracy-related penalty for 1996. Reviewed and adopted as the report of the Small Tax Case Division. To reflect the foregoing, Decisions will be entered for respondent in docket No. 2730-01S and under Rule 155 in docket No. 2731-01S.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
Last modified: May 25, 2011