- 8 - 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. The facts of this case do not support petitioner. She sponsored an activity for the purpose of generating income, and in which she was quite successful. There is little argument, if any, that can be made for petitioners’ exoneration of this penalty, nor have petitioners advanced any argument. Respondent is sustained on this issue. Reviewed and adopted as the report of the Small Tax Case Division. Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011