- 17 - by-case basis, taking into account all the pertinent facts and circumstances. Sec. 1.6664-4(b)(1), Income Tax Regs. The taxpayer’s education, experience, and knowledge are considered in determining reasonable cause and good faith. And, generally, the most important factor is the extent of the taxpayer’s effort to assess his or her proper tax liability. Sec. 1.6664-4(b)(1), Income Tax Regs. Respondent determined an accuracy-related penalty under section 6662(a) to be applicable in this case because petitioners understated their income tax by $10,048 on their 2002 return. Because petitioners’ understatement of tax was greater than 10 percent of the tax required to be shown on the return, or $5,000, the understatement was a substantial understatement of income tax pursuant to section 6662(d)(1)(A)(i) and (ii). Petitioners argue that they should not be held liable for the penalty because of their reliance on the income tax preparation provided to them by Mr. Ingram. Respondent carries the burden of production under section 7491(c) with respect to the accuracy-related penalty under section 6662. To meet that burden, respondent must come forward with sufficient evidence indicating that it is appropriate to impose the penalty. Higbee v. Commissioner, 116 T.C. 438, 446 (2001). Although respondent bears the burden of production with respect to the penalty, respondent “need not introduce evidencePage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 NextLast modified: March 27, 2008