- 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