Irene E. Jones, a.k.a. Irene E. Perry-Jones a.k.a. Irene E. Perry - Page 25

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          v. Boyle, 469 U.S. 241 (1985); Radabaugh v. Commissioner, T.C.              
          Memo. 1992-572.  Therefore, we hold that petitioner is liable for           
          additions to tax under section 6651(a)(1) for the years 1993 and            
          1994.                                                                       
          5.  Section 6662(a) Penalties                                               
               Section 6662(a) imposes a penalty of 20 percent of the                 
          portion of the underpayment which is attributable to negligence             
          or disregard of rules or regulations.  Sec. 6662(b)(1).                     
          Negligence is the lack of due care or failure to do what a                  
          reasonable and ordinarily prudent person would do under the                 
          circumstances.  Neely v. Commissioner, 85 T.C. 934, 947 (1985).             
          The term "disregard" includes any careless, reckless, or                    
          intentional disregard.  Sec. 6662(c).  Based on this record, we             
          hold that petitioner was negligent and disregarded rules or                 
          regulations.  Accordingly, she is liable for the accuracy-related           
          penalties under section 6662(a) for 1993 and 1994.                          
               To reflect the concessions and our conclusions on the                  
          disputed issues,                                                            
                                                  Decision will be entered            
                                             under Rule 155.                          












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