- 22 - 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.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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