Clyde E. Owens and Marie W. Owens - Page 23

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               We conclude that petitioners did not establish their right             
          to more deductions or cost of goods sold than respondent allowed            
          for 1989 and 1990.                                                          
          D.   Self-Employment Tax                                                    
               Respondent determined that petitioners are liable for self-            
          employment tax under section 1401 and that they may deduct one-             
          half of the self-employment tax they paid under section 164(f).             
          Petitioners concede that they were each self-employed.  We                  
          sustain respondent's determination on this issue.                           
          E.   Whether Petitioners Are Liable for the Accuracy-Related                
               Penalty Under Section 6662(a)                                          
               Respondent determined that petitioners are liable for the              
          accuracy-related penalty for negligence for 1989 and 1990 under             
          section 6662(a) and (c).  Petitioners contend that they are not             
          liable for the accuracy-related penalty for negligence.  We                 
          disagree.                                                                   
               Taxpayers are liable for a penalty equal to 20 percent of              
          the part of the underpayment to which section 6662 applies.  Sec.           
          6662(a).  Negligence is a lack of due care or failure to do what            
          a reasonable and ordinarily prudent person would do under the               
          circumstances.  Zmuda v. Commissioner, 731 F.2d 1417, 1422 (9th             
          Cir. 1984), affg. 79 T.C. 714 (1982); Neely v. Commissioner, 85             
          T.C. 934, 947 (1985).  For purposes of section 6662(a),                     
          negligence is a failure to reasonably attempt to comply with the            
          Internal Revenue Code.  Sec. 6662(c).  The accuracy-related                 





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