Jason Emanuel Ayala - Page 8




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          disregard of the rules or regulations.  Sec. 6662(b)(1).                    
          “‘[N]egligence’ includes any failure to make a reasonable attempt           
          to comply with the [Internal Revenue Code], and the term                    
          ‘disregard’ includes any careless, reckless, or intentional                 
          disregard.”  Sec. 6662(c).                                                  
               Petitioner does not have a bank account, and his credit                
          cards are billed to his father.  Petitioner’s mother assists him            
          by handling his finances and acting as his bookkeeper.  Working             
          for Sheehan is the first job he has had, and petitioner often               
          pays taxes in several states in addition to his Federal income              
          tax.  He strikes us as a hardworking young man who does his best            
          to comply with his tax responsibilities.                                    
               Given the facts presented in this case, as well as                     
          petitioner’s honest and straightforward testimony, we are                   
          convinced that the reasonable cause and good faith provisions of            
          section 6664(c)(1) are applicable here.  Accordingly, we decide             
          in favor of petitioner on this issue.                                       
          C.  Conclusion                                                              
               We find that petitioner’s family’s home in Vallejo was not             
          his tax home for Federal tax purposes during the years in issue.            
          Rather, his tax home was wherever he happened to be, and                    
          consequently, petitioner had no home from which to be away for              
          purposes of claiming deductions for travel expenses under section           
          162(a)(2).                                                                  







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