- 7 - 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).Page: Previous 1 2 3 4 5 6 7 8 9 NextLast modified: November 10, 2007