Wilburn C. Hall, Jr. - Page 67

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        imposes an addition to tax of 5 percent of the underpayment if                
           any part of the underpayment is due to negligence or                       
        intentional disregard of rules or regulations. Section 6653(a)(2)             


             20(...continued)                                                         
                              (A) with respect to the portion of the                  
                         underpayment described in paragraph (1) which is             
                         attributable to the negligence or intentional                
                         disregard referred to in paragraph (1),* * *                 
                              Sec. 6653(a), as in effect for 1986,                    
                         provides in pertinent part, as follows:                      
                              SEC. 6653.  ADDITIONS TO TAX FOR NEGLIGENCE             
                         AND FRAUD.                                                   
                    (a) Negligence.---                                                
                          (1) In general.--If any part of any underpayment            
                     (as, defined in subsection (c)) is due to negligence             
                     or disregard of rules or regulations, there shall be             
                     added to the tax an amount equal to the sum of--                 
                                (A) 5 percent of the underpayment, and                
                                (B) an amount equal to 50 percent of the              
                          interest payable under section 6601 with respect            
                          to the portion of such underpayment which is                
                          attributable to negligence for the period                   
                          beginning on the last date prescribed by law for            
                          payment of such underpayment (determined without            
                          regard to any extension) and ending on the date             
                          of the assessment of the tax (or, if earlier,               
                          the date of the payment of the tax).                        
                     The later amendment of this provision by sec.                    
                1015(b)(2)(A) of the Technical and Miscellaneous Revenue              
                Act of 1988, Pub. L. 100-647, 102 Stat. 3342, 3569, does              
                not affect the instant case.                                          
                     As a result of secs. 7721(a) and 7721(c)(1) of the               
                omnibus Budget Reconciliation Act of 1989 (OBRA 89), Pub.             
                L. 101-239, 103 Stat. 2106, 2395, 2399, the revised                   
                negligence, etc., addition to tax now appears in subsecs.             
                (b)(1) and (c) of sec. 6662, I.R.C. 1986.                             






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