Virgie R. Porter - Page 9




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               Section 6662 imposes an accuracy-related penalty “equal to             
          20 percent of the portion of the underpayment” of tax                       
          attributable to “Any substantial understatement of income tax.”             
          Sec. 6662(a) and (b)(2).  A substantial understatement of income            
          tax exists if the amount of the understatement for the taxable              
          year exceeds the greater of 10 percent of the tax required to be            
          shown on the return for the taxable year, or $5,000.  Sec.                  
          6662(d)(1)(A).                                                              
               However, “No penalty shall be imposed * * * if it is shown             
          that there was a reasonable cause * * * and that the taxpayer               
          acted in good faith”.  Sec. 6664(c).  Petitioner failed to                  
          address the accuracy-related penalty at trial and offered no                
          evidence that she had reasonable cause for the understatement or            
          acted in good faith.  Accordingly, we sustain respondent’s                  
          determination.                                                              
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To reflect the foregoing,                                              
                                             Decision will be entered                 
                                        for respondent.                               













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