110 T.C. No. 26 UNITED STATES TAX COURT ALBERT LEMISHOW, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent* Docket No. 18744-96. Filed June 2, 1998. P is liable for the accuracy-related penalty on that portion of the underpayment attributable to the negligent omission of $102,519 of the total unreported income. In determining the amount to which the penalty is applied, R first calculated the total underpayment. R then calculated the underpayment excluding the "negligent" income. R then imposed the penalty on the difference. P calculated the underpayment of tax attributable to negligence by adding the $102,519 to the reported income and applying the penalty to that amount. Held, R's method of computing the penalty is sustained. J. Dudley B. Kimball, for petitioner. Mark L. Hulse and Laurence D. Ziegler, for respondent. 1 This supplements Lemishow v. Commissioner, 110 T.C. 110 (1998).Page: 1 2 3 4 5 6 7 Next
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