Brad and Teri Montagne - Page 12

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          understatement exceeds the greater of $5,000 or 10 percent of the           
          amount of tax required to be shown on a return.  Sec.                       
          6662(d)(1)(A).                                                              
               Whether applied because of a substantial understatement of             
          tax or negligence or disregard of rules or regulations, the                 
          accuracy-related penalty is not imposed with respect to any                 
          portion of the underpayment as to which the taxpayer acted with             
          reasonable cause and in good faith.  Sec. 6664(c)(1).  The                  
          decision as to whether the taxpayer acted with reasonable cause             
          and in good faith depends upon all the pertinent facts and                  
          circumstances.  Sec. 1.6664-4(b)(1), Income Tax Regs.                       
               Respondent determined tax deficiencies of $17,091 and                  
          $17,867 for 1997 and 1998, respectively.  Petitioners conceded at           
          trial that respondent’s adjustments to petitioners’ tax liability           
          in the notice of deficiency were correct, with the exception of             
          self-employment tax.  We have found for respondent on the issues            
          of petitioners’ self-employment tax liability and the                       
          deductibility of losses from their horse activity.  Respondent              
          has met his burden of production.  Petitioners did not present              
          any evidence indicating reasonable cause or substantial                     
          authority.  See secs. 6662, 6664.  Accordingly, we sustain                  
          respondent’s penalty determination.                                         
               B.  Addition to Tax                                                    
               Respondent determined that petitioners are liable for an               






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