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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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