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Commissioner, 526 F.2d 1 (9th Cir. 1975), affg. T.C. Memo.
1974-243.
Petitioners also claim that they were damaged by employees
of the IRS. We have refrained from quoting at length their
reckless and inflammatory rhetoric, because to do so would be to
exacerbate an unfortunate situation. The record does not
substantiate petitioners' accusations of misconduct on the part
of IRS employees.
The only bona fide issue in this case is applicability of
the section 6662 penalty. Section 6662 provides in pertinent
part as follows:
SEC. 6662. IMPOSITION OF ACCURACY-RELATED
PENALTY.
(a) Imposition of Penalty.--If this section
applies to any portion of an underpayment of tax
required to be shown on a return, there shall be added
to the tax an amount equal to 20 percent of the portion
of the underpayment to which this section applies.
(b) Portion of Underpayment to Which Section
Applies.--This section shall apply to the portion of
any underpayment which is attributable to 1 or more of
the following:
(1) Negligence or disregard of rules or
regulations.
(2) Any substantial understatement of income
tax.
* * * * * * *
(c) Negligence.--For purposes of this section, the
term "negligence" includes any failure to make a
reasonable attempt to comply with the provisions of
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