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the necessary return. Thus, we sustain respondent's
determination.
Finally, respondent determined that petitioners are liable
for an accuracy-related penalty under section 6662. Section
6662(a) imposes a penalty in an amount equal to 20 percent of the
underpayment of tax attributable to one or more of the items set
forth in section 6662(b). Respondent asserts that the entire
underpayment in issue was due to petitioners' negligence or
disregard of rules or regulations. Sec. 6662(b)(1). Petitioners
bear the burden of proving that respondent's determination is
erroneous. Rule 142(a); Bixby v. Commissioner, 58 T.C. 757, 791
(1972).
"Negligence" includes a failure to make a reasonable attempt
to comply with the provisions of the internal revenue laws. Sec.
6662(c); sec. 1.6662-3(b)(1), Income Tax Regs. A position with
respect to an item is attributable to negligence if it lacks a
reasonable basis. Sec. 1.6662-3(b)(1), Income Tax Regs.
"Disregard" includes any careless, reckless, or intentional
disregard of rules or regulations. Sec. 6662(c); sec. 1.6662-
3(b)(2), Income Tax Regs. Petitioners have offered no evidence
in this case to demonstrate that the underpayment in question was
not attributable to their negligence or disregard of rules or
regulations. Accordingly, we sustain respondent's determination.
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