- 21 - 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.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011