- NEXTRECORD -
Posting date Amount
4/01/91 $165.57
7/01/91 152.54
10/01/91 166.61
12/31/91 141.35
Total 626.07
The record also demonstrates that petitioner only reported $100
of interest income on his 1991 income tax return. Accordingly,
we sustain respondent's determination and hold that petitioner
failed to report interest income in the amount of $526.
Issue (3): Accuracy-related Penalty
Section 6662(a) and (b)(1) provides that if any portion of
an underpayment of tax is attributable to negligence or disregard
of rules or regulations, then there shall be added to the tax an
amount equal to 20 percent of the amount of the underpayment that
is so attributable.16 The term "negligence" includes any failure
to make a reasonable attempt to comply with the statute, and the
term "disregard" includes any careless, reckless, or intentional
disregard. Sec. 6662(c).
By virtue of section 6664(c)(1), the accuracy-related
penalty is not imposed with respect to any portion of an
16 The accuracy-related penalty may also be applicable if
there is an underpayment of tax that is attributable to a
substantial understatement of income tax. Sec. 6662(a), (d).
Respondent conceded that there is no underpayment of tax in the
present case that is attributable to a substantial understatement
as defined by sec. 6662(d)(1)(A) and (2)(A).
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