- 19 - Beginning Ending Inventory Inventory Crystal (horse) -0- -0- Midnight (horse) -0- -0- Rags (horse) -0- $600 Winston (horse) -0- -0- Sparky (dog) $150 150 Wanda (dog) 200 200 Buddy (dog) 220 220 Bubbles -0- -0- 2 pups -0- -0- Total 570 1,170 Since petitioner substantiated $2,100 of materials and supplies and $600 of purchases, her total allowable costs for 1993 are $2,100 ($2,100 + 600 + (570 - 1,170)). Section 6662(a) Accuracy-Related Penalty Section 6662(a) imposes a penalty in an amount equal to 20 percent of the portion of the underpayment of tax attributable to one or more of the items set forth in section 6662(b), such as negligence or disregard of rules or regulations. Respondent determined that the entire underpayment of petitioner's tax was due to negligence or intentional disregard of rules or regulations. Sec. 6662(b)(1). As is the case of the predecessor section covering the addition to tax for negligence, section 6653(a), petitioner bears the burden of proof on the penalties in issue. Rule 142(a); Neely v. Commissioner, 85 T.C. 934, 947 (1985). Negligence includes a failure to make a reasonable attempt to comply with the provisions of the internal revenue laws. Sec. 6662(c); sec. 1.6662-3(b)(1), Income Tax Regs. Negligence is the failure to exercise due care or the failure toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011