- 18 - attributable to the unreported $322,500 is attributable to negligence. See sec. 6662(b); Niedringhaus v. Commissioner, 99 T.C. 202, 220 (1992). However, the portion of the underpayment of tax attributable to the rent-free use of the new apartment in 1989 is not insulated from the section 6662 penalty. Petitioners argue that petitioner reasonably relied on the advice of Spyropoulos as to the tax ramifications of the surrender agreement and the sublease agreement. Spyropoulos did not provide petitioners with tax advice. Petitioners' argument that they reasonably relied on Spyropoulos is without merit. We conclude that the portion of the underpayment of tax attributable to the rent-free use of the new apartment in 1989, and the entire underpayments of tax for the taxable years 1990 and 1991 are attributable to negligence. To reflect the foregoing and the concessions by the parties, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18
Last modified: May 25, 2011