Nada Nahhas - Page 16

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          Sec. 6662(a) and (b)(1).  The term “negligence” includes any                
          failure to make a reasonable attempt to comply with the                     
          provisions of the internal revenue laws or to exercise ordinary             
          and reasonable care in the preparation of a tax return.  Sec.               
          6662(c); Gowni v. Commissioner, T.C. Memo. 2004-154.  The term              
          “disregard” includes any careless, reckless, or intentional                 
          disregard.  Sec. 6662(c); sec. 1.6662-3(b)(2), Income Tax Regs.             
               The accuracy-related penalty does not apply to any part of             
          an underpayment for which there was reasonable cause and with               
          respect to which the taxpayer acted in good faith.  Sec.                    
          6664(c)(1); sec. 1.6664-4(a), Income Tax Regs.  The determination           
          of whether a taxpayer acted with reasonable cause and in good               
          faith is made on a case-by-case basis, taking into account all              
          pertinent facts and circumstances.  Sec. 1.6664-4(b)(1), Income             
          Tax Regs.  Generally, the most important factor is the extent of            
          the taxpayer’s effort to assess the taxpayer’s proper tax                   
          liability.  Id.  Here, the income tax return in question was                
          prepared by someone from Abbasi Accounting and Tax Services.  We            
          note that on line 11 of the income tax return for reporting                 
          “Alimony received” the amount of $105,600 originally reported was           
          lined-out.  As previously noted this amount represents $13,200              
          received for 8 months in 2002.  Petitioner reported only $13,915            
          of Schedule C income.  Evidently, either the tax return preparer            

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