Stephen P. and Jutta A. Maranto - Page 13

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          the necessary return.  Thus, we sustain respondent's                        
          determination.                                                              
               Finally, respondent determined that petitioners are liable             
          for an accuracy-related penalty under section 6662.  Section                
          6662(a) imposes a penalty in an amount equal to 20 percent of the           
          underpayment of tax attributable to one or more of the items set            
          forth in section 6662(b).  Respondent asserts that the entire               
          underpayment in issue was due to petitioners' negligence or                 
          disregard of rules or regulations.  Sec. 6662(b)(1).  Petitioners           
          bear the burden of proving that respondent's determination is               
          erroneous.  Rule 142(a); Bixby v. Commissioner, 58 T.C. 757, 791            
          (1972).                                                                     
               "Negligence" includes a failure to make a reasonable attempt           
          to comply with the provisions of the internal revenue laws.  Sec.           
          6662(c); sec. 1.6662-3(b)(1), Income Tax Regs.  A position with             
          respect to an item is attributable to negligence if it lacks a              
          reasonable basis.  Sec. 1.6662-3(b)(1), Income Tax Regs.                    
          "Disregard" includes any careless, reckless, or intentional                 
          disregard of rules or regulations.  Sec. 6662(c); sec. 1.6662-              
          3(b)(2), Income Tax Regs.  Petitioners have offered no evidence             
          in this case to demonstrate that the underpayment in question was           
          not attributable to their negligence or disregard of rules or               
          regulations.  Accordingly, we sustain respondent's determination.           







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