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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note that sections 6653 and 6661 were repealed effective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).
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