William E. and Karen L. Kivett - Page 9

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          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               

                                            Decision will be entered                  
                                       for respondent.                                

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