- 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 Next
Last modified: November 10, 2007