- 12 - important factor in determining reasonable cause and good faith is the extent of the taxpayer’s effort to assess his proper tax liability. Sec. 1.6664-4(b)(1), Income Tax Regs. We may give weight to a taxpayer’s oral testimony regarding the fact and amount of his claimed deductions. Patterson v. Commissioner, T.C. Memo. 1972-82. However, we have declined to do so when the taxpayer did not make a good faith effort to reconstruct his expenses or provide any documentation or corroborative evidence 4(...continued) • Why the records were unavailable and what steps were taken to secure the records. • When and how the taxpayer became aware that they did not have the necessary records. • If other means were explored to secure needed information. • Why the taxpayer did not estimate the information. • If the taxpayer contacted the Service for instructions on what to do about missing information. • If the taxpayer promptly complied once the missing information was received; and • Supporting documentation such as copies of letters written and responses received in an effort to get the needed information. 6 Administration, Internal Revenue Manual (CCH), sec. 20.1.1.3.1.2.5, at 45,014 (Aug. 20, 1998).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011