- 2 - Addition to Accuracy-Related Tax Penalty Year Deficiency Sec. 6651(a)(1) Sec. 6662(a),(c)1 1990 $1,181.38 $6,503.94 $6,607.52 1991 -- 3,375.00 -- 1992 -- 2,404.00 -- 1 Respondent determined that petitioners were liable for negligence under sec. 6662(a) and (c), but not substantial understatement under sec. 6662(d). Thus, we do not consider whether petitioners are liable under sec. 6662(d). After concessions by petitioners, we must decide the following issues: 1. Whether petitioners' Applications for Automatic Extension of Time to File U.S. Individual Income Tax Return (Forms 4868) for the years in issue are valid. We hold that they are not, because petitioners did not properly estimate their tax liability. 2. Whether petitioners are liable for additions to tax under section 6651(a)(1) for failure to timely file income tax returns for 1990, 1991, and 1992. We hold that they are. 3. Whether petitioners are liable for the accuracy-related penalty under section 6662(a) and (c) for negligence for 1990. We hold that they are. 4. Whether imposition of the additions to tax for failure to timely file under section 6651(a)(1) and failure to timely pay under section 6651(a)(2) and the accuracy-related penalty for negligence under section 6662(a) and (c) for 1990 violates the Double Jeopardy Clause of the Fifth Amendment to the U.S.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011