- 21 - (viz., Sun Life, A.G. Edwards, and American General) would have been required to issue Forms 1099 (i.e., by no later than January 31, 2002). We turn now to petitioner’s claim at trial that she believed that the respective gross distributions made by Sun Life and A.G. Edwards during 2001 were death benefits that are not taxable because some of her widowed friends told her during informal discussions that death benefits are not taxable. We find that it was unreasonable for petitioner to rely on any such informal statements of her friends in concluding that the respective gross distributions that Sun Life and A.G. Edwards made during 2001 are not taxable. In determining whether a taxpayer acted with reasonable cause and in good faith, generally the most important factor to consider “is the extent of the taxpayer’s effort to assess the taxpayer’s proper tax liability.” Sec. 1.6664- 4(b)(1), Income Tax Regs. Petitioner should have consulted a professional, and not her friends, about the tax treatment of the respective gross distributions that Sun Life and A.G. Edwards made during 2001.15 The record does not establish, and peti- 15We note that the record does not establish that A.G. Edwards referred to the respective gross distributions that it made during 2001 as death benefits. The record shows that such distributions were from decedent’s IRA and petitioner’s IRA. Nor does the record establish that American General referred to the respective distributions that it made during 2001 as death benefits. The record shows that such distributions were of interest and other income. Although the record establishes that (continued...)Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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