Thomas B. Drummond - Page 45

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          November 1, 1991.  Yet, the parties agree that the application              
          for additional extension of time was filed in order to extend the           
          time within which to file his 1990 return to October 15, 1991.              
          On the record before us, we sustain respondent's determination              
          under section 6651(a)(1) for 1990 only to the extent that peti-             
          tioner filed his 1990 return after October 15, 1991.                        
               Section 6662(a)                                                        
               Respondent determined that petitioner is liable for the                
          years at issue for the accuracy-related penalty under section               
          6662(a) because a portion of the underpayment of tax for each of            
          those years was due to negligence, disregard of rules and regula-           
          tions, or a substantial understatement of income tax.                       
               Section 6662(a) imposes an addition to tax equal to 20                 
          percent of the underpayment of tax attributable to, inter alia,             
          (1) negligence or disregard of rules or regulations and (2) any             
          substantial understatement of income tax.  Sec. 6662(b)(1) and              
          (2).  For purposes of section 6662(a), the term "negligence"                
          includes any failure to make a reasonable attempt to comply with            
          the Code, and "disregard" includes any careless, reckless, or               
          intentional disregard.  Sec. 6662(c).  Negligence has also been             
          defined as a lack of due care or failure to do what a reasonable            
          person would do under the circumstances.  Leuhsler v. Commis-               
          sioner, 963 F.2d 907, 910 (6th Cir. 1992), affg. T.C. Memo.                 
          1991-179; Antonides v. Commissioner, 91 T.C. 686, 699 (1988),               
          affd. 893 F.2d 656 (4th Cir. 1990).  With respect to individuals,           





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