Allied Marine Systems, Inc. - Page 22

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          Section 6662 Penalty                                                        
               Respondent determined that petitioner is liable for the                
          section 6662(a) penalty for 1989.  Section 6662(a) imposes an               
          accuracy-related penalty in an amount equal to 20 percent of the            
          underpayment of tax attributable to one or more of the items set            
          forth in section 6662(b).  On brief, respondent argues that the             
          determination of the section 6662(a) penalty should be sustained            
          because petitioner's underpayment was due to negligence or due to           
          a substantial understatement.  Sec. 6662(b)(1) and (2).  The                
          deficiency here determined is a substantial understatement.  See            
          sec. 6662(d)(1).                                                            
               The accuracy-related penalty does not apply with respect to            
          any portion of an underpayment if it is shown that there was                
          reasonable cause for such portion of an underpayment and that               
          petitioner acted in good faith with respect to such portion.                
          Sec. 6664(c)(1).  The determination of whether petitioner acted             
          with reasonable cause and in good faith depends upon the                    
          pertinent facts and circumstances.  Sec. 1.6664-4(b)(1), Income             
          Tax Regs.  The most important factor is the extent of the                   
          taxpayer's effort to assess his or her proper tax liability for             
          the year.  Id.  Reliance by the taxpayer on the advice of a                 
          qualified adviser will constitute reasonable cause and good faith           
          if, under all of the facts and circumstances, the reliance by the           








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