Deborah Y. and Donald J. Everhart - Page 16

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          and in good faith is made on a case-by-case basis, taking into              
          account all the pertinent facts and circumstances.  Sec. 1.6664-            
          4(b)(1), Income Tax Regs.  The most important factor is the                 
          extent of the taxpayer’s effort to assess his proper tax                    
          liability for the year.  Id.                                                
               It is clear that petitioner was negligent with respect to              
          the $12,068 that was received by him through his general                    
          contracting business.  Petitioner did not keep adequate books and           
          records, or otherwise substantiate the $12,068, as required by              
          the Internal Revenue Code.  Thus, the amount of the accuracy-               
          related penalty applicable to petitioners’ unreported income for            
          taxable year 2000 requires computation from the foregoing.                  
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To reflect petitioners’ concessions and our resolution of              
          the disputed matters,                                                       
                                             Decision will be entered                 
                                        under Rule 155.                               
















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