William M. Hawkins and Laura C. Hawkins - Page 13

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          include any failure to make a reasonable attempt to comply with             
          the provisions of the Internal Revenue Code.  Sec. 6662(c).  It             
          is further defined as the failure to do what a reasonable person            
          with ordinary prudence would do under the same or similar                   
          circumstances.  Neely v. Commissioner, 85 T.C. 934, 947 (1985).             
          Disregard is defined to include any careless, reckless, or                  
          intentional disregard.  Sec. 6662(c).  An accuracy-related                  
          penalty will not be imposed with respect to any portion of an               
          underpayment as to which the taxpayer acted with reasonable cause           
          and in good faith.  Sec. 6664(c)(1).  Whether the taxpayer acted            
          with reasonable cause and in good faith depends on the pertinent            
          facts and circumstances.  Sec. 1.6664-4(b)(1), Income Tax Regs.             
          Circumstances that may indicate reasonable cause and good faith             
          include the extent of the taxpayer’s effort to properly assess              
          the tax liability and an honest misunderstanding of fact or law             
          that is reasonable in light of the taxpayer’s experience,                   
          knowledge, and education.  Id.  The taxpayer bears the burden of            
          proving that he or she did not act negligently or disregard rules           
          or regulations.  Rule 142(a); Welch v. Helvering, 290 U.S. 111,             
          115 (1933).                                                                 
               Petitioner is not an unsophisticated taxpayer but an                   
          experienced attorney, licensed since 1971.  He operates his own             
          law practice and owns approximately 18 investment properties.               
          This experience is relevant in deciding whether he acted                    






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