Charles A. Greene and Christine J. Greene - Page 26

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          addition should be computed based only on the interest accruing             
          on the underpayment that existed between the filing of the                  
          original 1983 return and the filing of the amended return in                
          1986.                                                                       
               Section 6653(a)(1) provides that if any part of any                    
          "underpayment" of tax is due to negligence, there shall be added            
          to the tax an amount equal to 5 percent of the "underpayment".              
          Under section 6653(a)(2), in addition to the above amount, there            
          shall be added to the tax an amount equal to 50 percent of the              
          interest due with respect to the portion of the "underpayment"              
          that is due to negligence.                                                  
               For purposes of section 6653, the term "underpayment" is               
          defined in section 6653(c)(1) for income tax as:                            
               a deficiency as defined in * * * [section 6211] (except                
               that, for this purpose, the tax shown on a return                      
               referred to in section 6211(a)(1)(A) shall be taken                    
               into account only if such return was filed on or before                
               the last day prescribed for the filing of such return,                 
               determined with regard to any extension of time for                    
               such filing) * * *                                                     
                                                                                     
          Therefore, for purposes of determining the existence and amount             
          of any "underpayment" of tax for purposes of the negligence                 
          additions of section 6653(a)(1) and (2), the additional tax shown           
          on petitioners' amended return for 1983 cannot be considered.10             
          Crocker v. Commissioner, 92 T.C. 899, 916 (1989); Emmons v.                 


               10The last date prescribed for filing petitioners' Federal             
          income tax return for 1983 was Apr. 15, 1984.  Secs. 6672, 6012.            




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