Allie Ray McCullen and Shurley G. McCullen - Page 22

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          that petitioner's corporation paid other interest that                      
          petitioners erroneously deducted on their income tax returns for            
          1990 and 1991.  Respondent contends that petitioner's corporation           
          may have paid some of the interest.  We disagree.  The Form 1098            
          bears petitioner's Social Security number, and it was addressed             
          to petitioner, not his corporation.  We conclude that petitioner            
          paid $8,126 to First Hanover Bank in 1990.5                                 
          F.   Whether Petitioners Are Liable for the Accuracy-Related                
               Penalty Under Section 6662(a)                                          
               Petitioners contend that they are not liable for the                   
          accuracy-related penalty for negligence for 1990 and 1991 under             
          section 6662(a) and (c).  They contend that they acted reasonably           
          under the circumstances.  We disagree.                                      
               Taxpayers are liable for a penalty equal to 20 percent of              
          the portion of the underpayment to which section 6662 applies.              
          Sec. 6662(a).  For purposes of section 6662(a), negligence                  
          includes any failure to make a reasonable attempt to comply with            
          the provisions of the Internal Revenue Code.  Sec. 6662(c).  The            
          accuracy-related penalty under section 6662(a) does not apply to            
          any part of an underpayment if the taxpayer shows that there was            
          reasonable cause for that part of the underpayment and that the             
          taxpayer acted in good faith.  Sec. 6664(c)(1).                             



               5 This is personal interest for reasons discussed above at             
          par. C-1.                                                                   




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