Jimie R. and Sandra Herlitschek Overby - Page 8

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          with the provisions of the Internal Revenue Code.  Sec. 6662(c).            
          “Disregard” consists of any careless, reckless, or intentional              
          disregard.  Id.                                                             
               An exception applies to the accuracy-related penalty when              
          the taxpayer demonstrates (1) there was reasonable cause for the            
          underpayment, and (2) he or she acted in good faith with respect            
          to such underpayment.  See sec. 6664(c).  Whether the taxpayer              
          acted with reasonable cause and in good faith is determined by              
          the relevant facts and circumstances.  The most important factor            
          is the extent of the taxpayer’s effort to assess the proper tax             
          liability.  See Stubblefield v. Commissioner, T.C. Memo. 1996-              
          537; sec. 1.6664-4(b)(1), Income Tax Regs.  Section 1.6664-                 
          4(b)(1), Income Tax Regs., specifically provides in part:                   
          “Circumstances that may indicate reasonable cause and good faith            
          include an honest misunderstanding of fact or law that is                   
          reasonable in light of the experience, knowledge and education of           
          the taxpayer.”                                                              
               It is the taxpayer’s responsibility to establish he or she             
          is not liable for the accuracy-related penalty imposed by section           
          6662(a).  See Rule 142(a).  Petitioners failed to explain                   
          adequately why they did not report all of their income for 1995.            
          On the basis of the entire record, we conclude that petitioners             
          have not established that the underpayment of tax was due to                








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