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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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Last modified: May 25, 2011