- 14 - attempt at accurately reporting the bad debt. The fact that petitioner mistakenly placed the $86,040 deduction on the wrong line on the first page of the 1996 return corresponds with his confusion in using Schedule D. On the basis of petitioners’ position and their reporting on page 1 of their 1996 return, they should have reported the loss on Schedule C. Even if petitioners had used a Schedule C, respondent contends that they would have been negligent because the loss should have been shown on a Schedule A as an itemized deduction. In light of petitioner’s educational background, the circumstances of this case, and the multiplicity of possibilities for claiming business bad debts, petitioner has shown good faith and reasonable cause for the way he reported the bad debt deduction. We hold that the accuracy-related penalty does not apply to the portion of the understatement attributable to the adjustment concerning the bad debt. Petitioners concede that they failed to report income from interest, a State tax refund, and pensions in the total amount of $33,415, resulting in a substantial underreporting of income. Petitioners further concede that they “missed” or overlooked Forms 1099 with the result that they underreported income. The unreported income was substantial in amount because the understatement of income tax exceeds the greater of 10 percent of the tax required to be shown on the tax return or $5,000. ThePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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