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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).
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