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The final issue is respondent’s determination that
petitioners are liable for the section 6662(a) accuracy-related
penalty.
Section 6662(a) imposes an accuracy-related penalty in the
amount of 20 percent on any portion of an underpayment of tax
that is attributable to causes set forth in subsection (b).
However, under section 6664(c), no penalty shall be imposed under
section 6662(a) with respect to any portion of an underpayment if
it is shown that there was a reasonable cause for the
underpayment and that the taxpayer acted in good faith with
respect to the underpayment.
The determination of whether a taxpayer acted with
reasonable cause and in good faith is made on a case-by-case
basis. Sec. 1.6664-4(b), Income Tax Regs. The most important
factor is the extent of the taxpayer’s effort to assess the
taxpayer’s proper tax liability. See id. An honest
misunderstanding of fact or law that is reasonable in light of
the experience, knowledge, and education of the taxpayer may
indicate reasonable cause and good faith. Remy v. Commissioner,
T.C. Memo. 1997-72. Here, petitioner is an attorney with a
specialized degree in tax law who was employed as an auditor by
the IRS for several years. His education, knowledge, and
experience in that field place him in a category that few
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