Gregory Eugene Thompson - Page 10




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          into account all the pertinent facts and circumstances, including           
          the taxpayer’s efforts to assess his or her proper tax liability            
          and the knowledge and experience of the taxpayer.  Sec. 1.6664-             
          4(b)(1), Income Tax Regs.  The taxpayer bears the burden of proof           
          with respect to reasonable cause.  Higbee v. Commissioner, supra            
          at 446.                                                                     
               Petitioner failed to assert any arguments that reasonable              
          cause existed.  Petitioner focused his arguments on why the                 
          distribution should not be treated as income, should not be                 
          subject to the additional tax, as well as tax-protester type                
          arguments that wages are not income.  Specifically, petitioner              
          did not argue and did not introduce any evidence that he acted              
          with reasonable cause or in good faith with respect to the                  
          underpayment for 2004.5                                                     
               After considering all of the facts and circumstances, we               
          find that petitioner has failed to establish that he had                    
          reasonable cause and acted in good faith with respect to the                
          underpayment.  Accordingly, we sustain respondent’s determination           
          that petitioner is liable for the accuracy-related penalty for              
          2004.                                                                       



               5Petitioner states that the Code is difficult for the IRS to           
          understand, relying on a case involving the recovery of                     
          attorney’s fees.  McKee v. Commissioner, T.C. Memo. 2004-115, as            
          supplemented T.C. Memo. 2004-169, revd. 209 Fed. Appx. 691 (9th             
          Cir. 2006).  There is no uncertainty about petitioner’s legal               
          obligations here.  See, e.g., Pessin v. Commissioner, 59 T.C.               
          473, 489 (1972); Rosanova v. Commissioner, T.C. Memo. 1985-306;             
          Grant v. Commissioner, T.C. Memo. 1980-242.                                 





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