- 10 - are, therefore, liable for the addition to tax for substantial understatement as determined by respondent. Respondent determined an addition to tax for negligence under section 6653(a)(1) for 1988 in the amount of $1,425 and an accuracy-related penalty for negligence under section 6662 for 1989 in the amount of $910. Section 6662(a) imposes a 20-percent accuracy-related penalty based upon any portion of an underpayment of tax required to be shown on a return if, as provided in section 6662(b), the underpayment is attributable, among other things, to negligence or disregard of rules or regulations, or any substantial understatement of income tax. Section 6662(c) includes in the definition of "negligence" any failure to make a reasonable attempt to comply with the Internal Revenue title. Petitioners have the burden of proof. Bixby v. Commissioner, 58 T.C. 757 (1972); see Grzegorzewski v. Commissioner, T.C. Memo. 1995-49. They have failed to present any evidence refuting respondent's determination of negligence. Respondent's determination of negligence is sustained. To reflect the above, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011