William Spencer Bach and Barbara Ruth Bach - Page 15

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               Respondent also determined that petitioners are liable for             
          additions to tax under section 6653(a)(1)(A) and (B).  This Court           
          has defined negligence as a lack of due care or failure to do               
          what a reasonable and ordinarily prudent person would do under              
          the circumstances.  McGee v. Commissioner, 979 F.2d 66, 71 (5th             
          Cir. 1992), affg. T.C. Memo. 1991-510; Neely v. Commissioner, 85            
          T.C. 934, 947 (1985).  Respondent made numerous adjustments to              
          petitioners' income and deductions for 1987.  Petitioners have              
          not presented any evidence either at trial or on brief to                   
          convince us that their omissions from gross income and excess               
          deductions were not the result of negligence.  Therefore, we                
          sustain respondent's determination.                                         

          Additions to Tax for Substantial Understatement of Income Tax               

               The final issue for decision is whether petitioners are                
          liable for additions to tax under section 6661.  Section 6661(a)            
          provides for an addition to tax equal to 25 percent of the amount           
          of any underpayment attributable to a substantial understatement            
          of income tax.  Pallottini v. Commissioner, 90 T.C. 498, 503                
          (1988).  An understatement is substantial if it exceeds the                 
          greater of 10 percent of the tax required to be shown on the                
          return or $5,000.  Sec. 6661(b)(1)(A).  However, the amount of              
          the understatement may be reduced under section 6661(b)(2)(B) for           
          amounts adequately disclosed or supported by substantial                    
          authority.  Petitioners have not addressed this issue on brief,             




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