- 6 - 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.Page: Previous 1 2 3 4 5 6
Last modified: May 25, 2011