- 14 - Respondent determined that petitioner is liable for the additions to tax for failure to file timely returns for 1988, 1989, and 1990. Section 6651(a)(1) imposes an addition to tax in case of failure to file a timely tax return, unless the taxpayer can show that such failure is due to reasonable cause and not due to willful neglect. Petitioner neither argued nor offered any evidence to show that the additions to tax pursuant to section 6651(a)(1) should not be imposed. Therefore, we sustain respondent's determination under section 6651(a)(1). Respondent also determined that petitioner is liable for the addition to tax for substantial understatement of income tax, as prescribed by section 6661 with respect to his 1988 return. As in effect during 1988, section 6661(a) imposed an addition to tax equal to 25 percent of the amount of any underpayment attributable to a substantial understatement of income tax. Finally, respondent determined that petitioner is liable for the accuracy-related penalties prescribed by section 6662 with respect to his 1989, 1990, and 1991 returns. Section 6662(a) imposes a penalty equal to 20 percent of the portion of any underpayment attributable to a substantial understatement of income tax. Both sections 6661 and 6662 define a "substantial understatement" as an understatement of tax liability equal to the greater of 10 percent of the tax required to be shown for thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011