- 33 - resulted from the accountant's mistake. Therefore, we find that petitioner's reliance on West does not protect it from an addition to tax under section 6661. Given these considerations, we find that respondent did not abuse her discretion by not waiving the addition to tax. No reasonable cause existed for the understatement despite West's purported reliance on the prior audit and petitioner's purported reliance on West. Regardless, petitioner failed to request that respondent waive the addition to tax. We hold petitioner liable for an addition to tax under section 6661 for taxable year ended July 31, 1989. Accuracy-related Penalty Under Section 6662 Respondent determined an accuracy-related penalty of $28,170 under section 6662(a) for taxable year ended July 31, 1990. Section 6662(a) imposes a penalty in an amount equal to 20 percent of the portion of the underpayment of tax attributable to (1) negligence or disregard of the rules or regulations or (2) any substantial understatement of income tax. Sec. 6662(b)(1) and (2). The definition and the calculation of a substantial understatement under section 6662(d) are similar in most respects to section 6661. The section 6662(a) penalty does not apply to any portion of an underpayment for which reasonable cause exists and the taxpayer acted in good faith. Sec. 6664(c)(1). The taxpayer bears the burden of proving thatPage: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
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