Maurice E. Hodgkins and Barbara J. Hodgkins - Page 21

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          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, and           
          defines "disregard" as including "careless, reckless, or                    
          intentional disregard".  We need not extend this opinion by                 
          rehashing the many instances in each of the years in issue in               
          which petitioner carelessly, recklessly, or intentionally claimed           
          erroneous deductions or additions to basis.  They either knew or            
          should have known of these errors.  We therefore sustain                    
          respondent's determination.                                                 






















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