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amount of 20 percent on any underpayment to which the section
applies. Section 6662(b) applies to underpayments due to
negligence. Sec. 6662(b)(1). Negligence is the failure to make
a reasonable attempt to comply with the law. Sec. 6662(c).
Petitioner has not established that he used reasonable care in
preparing his return. Indeed, all of the deductions, except for
the safety shoes, are clearly not deductible. Thus, the entire
deficiency as redetermined is attributable to negligence.
Respondent's determination with respect to the penalty under
section 6662(a) is sustained.
Decision will be entered
for respondent.
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Last modified: May 25, 2011