The Escrow Connection, Inc., A.K.A. The Escrow Connection - Page 33

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          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 that             





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