- 7 - failure by a taxpayer to keep adequate books and records or to substantiate items properly. Sec. 1.6662-3(b), Income Tax Regs. An accuracy-related penalty is not imposed with respect to any portion of the underpayment as to which the taxpayer acted with reasonable cause and in good faith. Sec. 6664(c)(1); see Higbee v. Commissioner, supra at 448. This determination is based on all the relevant facts and circumstances. Higbee v. Commissioner, supra at 448; sec. 1.6664-4(b)(1), Income Tax Regs. “Relevant factors include the taxpayer’s efforts to assess his proper tax liability, including the taxpayer’s reasonable and good faith reliance on the advice of a professional such as an accountant.” Higbee v. Commissioner, supra at 448-449. Petitioner has failed to keep or produce adequate records. Respondent has provided sufficient evidence to meet his burden of production. Although petitioner had a background in tax law, she failed to show that she kept proper records to establish her entitlement to her claimed deductions. Petitioner has failed to show she acted with reasonable care or in good faith and has not produced reliable evidence to prove that respondent’s determination of negligence is incorrect. We hold thatPage: Previous 1 2 3 4 5 6 7 8 9 NextLast modified: November 10, 2007