- 20 - g. Self-employment Tax Deduction The amount of the allowable deduction for one-half of the self-employment tax imposed by section 1401 will be recomputed under Rule 155. Issue 3. Additions to Tax and Penalties Respondent determined additions to tax for late filing for all years in issue. Petitioner claimed that he was delayed in filing his returns because he moved his papers to different locations several times. The record does not support this assertion. Petitioner is therefore liable for the additions to tax for late filing as determined by respondent. Respondent determined an addition to tax for negligence under section 6653(a)(1) for 1988 and an accuracy-related penalty for negligence under section 6662(a) for 1989 and 1990. The addition to tax for negligence under section 6653(a)(1) is applicable if all or part of an underpayment of tax is due to negligence or intentional disregard of rules or regulations. The accuracy-related penalty under section 6662(a) is applicable if all or part of an underpayment of tax is attributable, among other things, to negligence or disregard of rules or regulations. We need not extend this opinion by rehashing the many instances in each of the years in issue in which petitionerPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011