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the pertinent facts and circumstances. Sec. 1.6664-4(b)(1),
Income Tax Regs.
With regard to claiming a filing status of single on their
tax returns for 1995 and 1996, we do not believe that petitioners
acted with reasonable cause and in good faith. See supra pp. 11-
12. Accordingly, we hold that petitioners are liable for the
accuracy-related penalties related to their claiming a filing
status of single on their tax returns for 1995 and 1996.
To reflect the foregoing,
An appropriate order will
be issued.
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