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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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