Juanita Carter - Page 23

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          question, petitioner failed to show that any such illnesses or              
          injuries incapacitated her to the point that she could not, with            
          reasonable effort, file on time her Federal income tax returns              
          for the years at issue.  The Court finds, on this record, that              
          petitioner's Federal income tax returns for 1990, 1991, and 1992            
          were not filed timely and that the late filings were not due to             
          reasonable cause.  Respondent, therefore, is sustained on this              
          issue.                                                                      
               The final issue is whether petitioner is liable for the                
          accuracy-related penalty under section 6662(a) for negligence or            
          disregard of rules or regulations, for 1989, 1990, 1991, and                
          1992.  Section 6662(a) provides that, if it is applicable to any            
          portion of an underpayment in taxes, there shall be added to the            
          tax an amount equal to 20 percent of the portion of the                     
          underpayment to which section 6662 applies.  Section 6662(b)(1)             
          provides that section 6662 shall apply to any underpayment                  
          attributable to negligence or disregard of rules or regulations.            
               Section 6662(c) provides that the term "negligence" includes           
          any failure to make a reasonable attempt to comply with the                 
          provisions of the Internal Revenue laws, and the term "disregard"           
          includes any careless, reckless, or intentional disregard of                
          rules or regulations.  Negligence is the lack of due care or                
          failure to do what a reasonable and ordinarily prudent person               







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