- 12 - 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). Respondent supports the imposition of the section 6662(a) accuracy-related penalty entirely on petitioner’s failure to include the Social Security disability benefits in his 1999 income. We are satisfied that petitioner made a good faith effort to properly determine his 1999 Federal income tax liability, and his failure to properly account for his Social Security disability benefits results from an honest misunderstanding of fact or law that is reasonable in light of the his experience, knowledge, and education. Accordingly, we hold that petitioner is not liable for the section 6662(a) accuracy-related penalty for his 1999 tax year. Reviewed and adopted as the report of the Small Tax Division. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13
Last modified: May 25, 2011