Rilwan Adisa Salami - Page 10

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               Section 6662(a) imposes a 20-percent penalty on the portion            
          of the underpayment attributable to any one of various factors,             
          one of which is negligence or disregard of rules or regulations.            
          Sec. 6662(b)(1).  Respondent determined that petitioner is liable           
          for the accuracy-related penalty imposed by section 6662(a) for             
          his underpayment of taxes, and that such underpayment was due to            
          negligence or disregard of rules or regulations.  "Negligence"              
          includes a failure to make a reasonable attempt to comply with              
          the provisions of the Internal Revenue laws or to exercise                  
          ordinary and reasonable care in the preparation of a tax return.            
          Sec. 6662(c); 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.                                                                   
               Section 6664(c)(1), however, provides that the penalty under           
          section 6662(a) shall not apply to any portion of an                        
          underpayment, if it is shown that there was reasonable cause for            
          the taxpayer's position with respect to that portion and that the           
          taxpayer acted in good faith with respect to that portion.  The             
          determination of whether a taxpayer acted with reasonable cause             
          and in good faith is made on a case-by-case basis, taking into              
          account all the pertinent facts and circumstances.  Sec.                    
          1.6664-4(b)(1), Income Tax Regs.  The most important factor is              
          the extent of the taxpayer's effort to assess his proper tax                
          liability for the year.  Id.                                                

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