Edward J. Richardson - Page 13

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          4.  Additions to Tax--Irene                                                  
               Respondent determined that Irene filed a delinquent return              
          for the taxable year 1988 and that she is liable for an addition             
          to tax under section 6651(a).  Section 6651(a) imposes an                    
          addition to tax for failure to file a timely return unless such              
          failure is due to reasonable cause.  Because we hold that Irene              
          received alimony required to be included in her gross income in              
          1988 and she has failed to show reasonable cause for the delin-              
          quent filing of her return, she is liable for an addition to tax             
          under section 6651(a) for 1988.                                              
               Respondent determined that Irene is liable for an addition              
          to tax under section 6661(a) for a substantial understatement of             
          tax for the taxable year 1988 and for accuracy-related penalties             
          under section 6662(b)(2) for substantial understatements of tax              
          for the taxable years 1989 and 1990.                                         
               Section 6661(a) provides for an addition to tax if there is             
          a substantial understatement of income tax.                                  
               Section 6661(c) authorizes the Commissioner to waive all or             
          any part of this addition to tax on a showing by the taxpayer                
          that there was reasonable cause for the understatement (or part              
          thereof) and that the taxpayer acted in good faith.                          
               Section 6662(a) and (b)(2) provides for an accuracy-related             
          penalty if there is a substantial understatement of tax.  Section            
          6664(c) provides that the section 6662 penalty is not imposed if             
          it is shown that the taxpayer had reasonable cause for the                   




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