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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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Last modified: May 25, 2011