- 29 - Additions to Tax and Penalty In the notices of deficiency, respondent determined that petitioners are liable for the additions to tax under sections 6653(a)(1)(A) and 6661 with respect to their 1987 returns, and for the penalty under section 6662(a) with respect to petitioners' 1989 returns. We note that sections 6653 and 6661 were repealed effective for returns due after December 31, 1989. See Omnibus Budget Reconciliation Act of 1989, Pub. L. 101-239, sec. 7721(c)(1) and (2), 103 Stat. 2399. During 1987, section 6653(a)(1)(A) imposed an addition to tax equal to 5 percent of the underpayment of tax if any part of the underpayment was due to negligence or disregard of rules or regulations. Also during 1987, section 6661 imposed an addition to tax for substantial understatement of income tax for any taxable year equal to 25 percent of the underpayment attributable to the understatement. Section 6662 imposes a penalty equal to 20 percent of the portion of an under- payment of tax which is attributable to negligence or disregard of the rules or regulations, or to a substantial understatement of income tax. Sec. 6662(b)(1) and (2).Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
Last modified: May 25, 2011