William Norwalk, Transferee, et al. - Page 28

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          presented no evidence to show that they acted with reasonable               
          cause or good faith.11  Therefore, we find that the accuracy-               
          related penalty under section 6662(a) applies to the underpayment           
          of tax associated with this settled issue.                                  
               In regard to the $40,000 deducted by the corporation as                
          consulting fees, we have upheld respondent's determination.                 
          After thoroughly reviewing the record in these cases, we find no            
          persuasive evidence or argument that the corporation acted with             
          reasonable cause or good faith with respect to this issue.  On              
          this record, we hold that the corporation negligently or                    
          intentionally disregarded rules or regulations with regard to the           
          underpayment of tax associated with this issue.  Accordingly, the           
          accuracy-related penalty under section 6662(a) is sustained with            
          respect to the underpayment of tax associated with this deduction           
          by the corporation.                                                         
               Mr. Norwalk reported his allocable portion of the dividend             
          ($16,680) on his return.  Even though he did not characterize               
          this amount as a dividend, the net effect of this was de minimis.           
          We find that any understatement attributable to this was not due            
          to negligence.  Thus, Mr. Norwalk is not liable for the accuracy-           
          related penalty under section 6662(a).                                      
          Transferee Liability                                                        


               11With respect to the adjustments in the notice of                     
          deficiency issued to Robert and Patricia DeMarta, the parties               
          filed a stipulation of settled issues with this Court on Oct. 24,           
          1997.                                                                       



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