Sam E. Scott - Page 23

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             percent addition to tax for failure to timely file his 1991 tax                                      
             return.                                                                                              
             Issue 5. Accuracy-Related Penalty                                                                    
                    The final issue for decision is whether petitioner is liable                                  
             for the accuracy-related penalty for the substantial understatement                                  
             of tax pursuant to section 6662.  Petitioner asserts that he had                                     
             reasonable cause for the understatement of tax.                                                      
                    Section 6662 imposes an accuracy-related penalty equal to 20                                  
             percent of any portion of an understatement attributable to a                                        
             substantial understatement.  A substantial understatement means an                                   
             understatement which exceeds the greater of 10 percent of the tax                                    
             required to be shown on the return or $5,000.  Sec. 6662(d)(1).                                      
             The understatement is reduced by that portion of the understatement                                  
             for which the taxpayer had substantial authority or for which the                                    
             taxpayer adequately disclosed the relevant facts in the return.                                      
             Sec. 6662(d)(2)(B).  Additionally, no penalty is imposed with                                        
             respect to any portion of an understatement as to which the                                          
             taxpayer acted with reasonable cause and in good faith.  Sec.                                        
             6664(c)(1).                                                                                          
                    Petitioner provided no disclosures in his return and supplied                                 
             this Court with no substantial authority for his positions.  See                                     
             sec. 1.6662-4(d)(3), Income Tax Regs.  Also, he failed to prove                                      
             that his effort to assess his proper tax liability was sufficient                                    
             to establish reasonable cause and good faith.  See sec. 1.6664-                                      





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