- 2 -
Accuracy-Related
Additions to Tax Penalty
Year Deficiency Sec. 6653(a)1 Sec. 6661 Sec. 66622
1985 $10,985 $549 $2,746 --
1986 8,076 404 2,019 --
1987 13,083 654 3,271 --
1988 1,961 98 -- --
1989 3,406 -- -- $578
1 Respondent determined that petitioner is liable for
additions to tax for 1986 and 1987 under sec. 6653(a)(1)(A)
and (B).
2 Respondent determined that petitioner is liable for
negligence under sec. 6662(a), not substantial understatement
or valuation misstatement. See sec. 6662(b), (c), (d), and (e).
Thus, we do not consider whether petitioner is liable under
sec. 6662(d) or (e).
The issues for decision are:
1. Whether petitioner had a deductible casualty loss of
$270,265 from the Loma Prieta earthquake in 1989 as petitioner
contends, zero as respondent contends, or some other amount. We
hold that her deductible casualty loss was $108,000 for 1988,
after reducing the amount of her loss by an insurance
reimbursement of $42,000.
2. Whether petitioner is liable for: (a) Additions to
tax for negligence under section 6653(a) for 1985 to 1988, (b)
additions to tax for substantial understatement under section
6661 for 1985 to 1987, and (c) the accuracy-related penalty under
section 6662 for 1989. We hold that she is not.
Section references are to the Internal Revenue Code in
effect for the years in issue. Rule references are to the Tax
Court Rules of Practice and Procedure.
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Last modified: May 25, 2011