- 15 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16
Last modified: May 25, 2011