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Regs. Disregard of rules or regulations includes any careless,
reckless, or intentional disregard. Sec. 1.6662-3(b)(2), Income
Tax Regs. The Commissioner bears the burden of production with
respect to the accuracy-related penalty. See sec. 7491(c);
Higbee v. Commissioner, 116 T.C. 438, 446 (2001).
Petitioner concedes that she did not maintain accounting
records for her business activities or mileage logs for her use
of the Trailblazer. Petitioner also concedes that she failed to
report gross receipts from Prepaid Legal Services. Petitioner
therefore failed to make a reasonable attempt to comply with the
law or maintain adequate records, and respondent has met his
burden of production. See sec. 6662(c); sec. 1.6662-3(b)(1),
Income Tax Regs.
An exception to the section 6662 penalty applies when the
taxpayer demonstrates there was reasonable cause for the
underpayment and the taxpayer acted in good faith with respect to
the underpayment. Sec. 6664(c). Whether the taxpayer acted with
reasonable cause and in good faith is determined by the relevant
facts and circumstances on a case-by-case basis. See
Stubblefield v. Commissioner, T.C. Memo. 1996-537; sec.
1.6664-4(b)(1), Income Tax Regs.
Petitioner testified that she had receipts for many of her
expenses but threw the receipts away when she moved her office
from one part of her house to another. Such circumstances do not
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