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Section 6653(a)(1)(A)17 (sec. 6653(a)(1), as to 1988)
imposes an addition to tax of 5 percent of the underpayment if
17 Sec. 6653(a), as in effect for 1986 and 1987, provides,
in pertinent part, as follows:
SEC. 6653. ADDITIONS TO TAX FOR NEGLIGENCE AND FRAUD.
(a) Negligence.--
(1) In general.--If any part of any underpayment
* * * is due to negligence or disregard of rules or
regulations, there shall be added to the tax an amount
equal to the sum of--
(A) 5 percent of the underpayment, and
(B) an amount equal to 50 percent of the
interest payable under section 6601 with respect
to the portion of such underpayment which is
attributable to negligence for the period
beginning on the last date prescribed by law for
payment of such underpayment (determined without
regard to any extension) and ending on the date of
the assessment of the tax (or, if earlier, the
date of the payment of the tax).
Sec. 6653(a), as in effect for 1988, provides, in pertinent
part, as follows:
SEC. 6653. ADDITIONS TO TAX FOR NEGLIGENCE AND FRAUD.
(a) Negligence.--
(1) In general.--If any part of any underpayment
(as defined in subsection (c)) of tax required to be
shown on a return is due to negligence (or disregard of
rules or regulations), there shall be added to the tax
an amount equal to 5 percent of the underpayment.
The later amendment of this provision by sec. 7721(c)(1) of
the Omnibus Budget Reconciliation Act of 1989 (OBRA 89), Pub. L.
101-239, 103 Stat. 2106, 2399, does not affect the instant case.
The substance of this provision now appears in subsecs. (b)(1)
and (c) of sec. 6662.
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