Allen and Mary Doxtator - Page 34

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          proper tax liability, including the taxpayer's reasonable and               
          good faith reliance on the advice of a tax professional.  See               
          id.; see also sec. 1.6664-4(c), Income Tax Regs. Further, an                
          honest misunderstanding of fact or law that is reasonable in                
          light of the experience, knowledge, and education of the taxpayer           
          may indicate reasonable cause and good faith.  See Remy v.                  
          Commissioner, T.C. Memo. 1997-72.                                           
               Petitioners assert that they had reasonable cause for the              
          various positions taken on all their returns.  In considering               
          this issue, we note that Mr. Doxtator was a well-informed                   
          taxpayer.  He was a volunteer tax return preparer for the IRS               
          between 1996 and 1998.  In these proceedings, he has cited                  
          taxation and Indian law authorities extensively.  Moreover, in              
          their previous case before this Court, petitioners claimed an               
          exemption from tax, based on their status as Native Americans,              
          for tier II railroad retirement benefits, but they failed to                
          identify any treaty or statute providing such an exemption.  Our            
          opinion to that effect was issued before any of the return                  
          positions at issue herein were taken.  In this context, we                  
          address petitioners' return positions.                                      
               We find no reasonable cause for petitioners' position that             
          Mrs. Doxtator's judicial officer compensation is not subject to             
          income tax in 1997 and 1999.  Petitioners disregarded information           







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