Susan Bocock and Jack Carl Ryals - Page 10

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          2395, repealed section 6661 and replaced it with section 6662.              
          Section 6664 was also enacted, defining the term “underpayment”.            
          Sections 6662(a) and 6664(a) provide, in pertinent part, as                 
          follows:                                                                    
               SEC. 6662.  IMPOSITION OF ACCURACY RELATED PENALTY ON                  
                         UNDERPAYMENTS.                                               
                    (a) Imposition of Penalty.--If this section                       
               applies to any portion of an underpayment of tax                       
               required to be shown on a return, there shall be added                 
               to the tax an amount equal to 20 percent of the portion                
               of the underpayment to which this section applies.                     
                    *       *       *        *       *       *       *                
               SEC. 6664.  DEFINITIONS AND SPECIAL RULES.                             
                    (a) Underpayment.--For purposes of this part, the                 
               term “underpayment” means the amount by which any tax                  
               imposed by this title exceeds the excess of–-                          
                    (1) the sum of--                                                  
                              (A) the amount shown as the                             
                         tax by the taxpayer on his return,                           
                         plus                                                         
                              (B) amounts not so shown                                
                         previously assessed (or collected                            
                         without assessment), over                                    
                    (2) the amount of rebates made. [Emphasis added.]                 
          Section 1.6664-2(d), Income Tax Regs., provides further guidance            
          regarding the phrase “collected without assessment” in section              
          6664(a)(1)(B):                                                              
                    (d) Amounts not so shown previously assessed (or                  
               collected without assessment).  * * * For purposes of                  
               [defining an underpayment for purposes of section                      
               6662], the amount "collected without assessment" is the                
               amount by which the total of the credits allowable                     





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