Caspian Consulting Group, Inc. - Page 3

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               On its 2000 Federal income tax return, petitioner deducted             
          the following amounts for the acquisition and operation of an               
          airplane:  Operating expenses of $23,033, interest expenses of              
          $29,742, and depreciation of $128,289.  Respondent disallowed               
          these deductions and determined that petitioner was liable for an           
          income tax deficiency of $43,698 and an accuracy-related penalty            
          of $8,740 for 2000.                                                         
                                       OPINION                                        
               Pursuant to section 6662(a), a taxpayer may be liable for a            
          penalty of 20 percent on the portion of an underpayment of tax              
          (1) due to negligence or disregard of rules or regulations or (2)           
          attributable to a substantial understatement of tax.  Sec.                  
          6662(b).  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.  Relevant             
          factors include the taxpayer’s efforts to assess his proper tax             
          liability, including the taxpayer’s reasonable and good faith               
          reliance on the advice of a professional such as an accountant.             
          See id.                                                                     






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