- 7 - deduction. The correct amounts will be recomputed under Rule 155. As noted, respondent determined an accuracy-related penalty under section 6662(a) in the amount of $2,226. Section 6662(a) imposes an accuracy-related penalty of 20 percent on any portion of an underpayment of tax that is attributable to items set forth in section 6662(b). Section 6662(b)(1) provides that section 6662(a) is to apply to any portion of an underpayment attributable to negligence or disregard of rules or regulations. Section 6662(b)(2) applies section 6662(a) to any substantial understatement of income tax. Section 6662(c) defines negligence to include any failure to make a reasonable attempt to comply with the provisions of the Internal Revenue Code, and defines "disregard" to include any careless, reckless, or intentional disregard of rules or regulations. Petitioner was an accountant who knew that he was not entitled to reduce his gross receipts by returns and allowances when he had not taken the sales price of the returned items into his income. Thus, we find and hold that petitioner demonstrated negligence or disregard of rules or regulations. There is a substantial understatement of income tax if thePage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011