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under section 6651(a)(1) and additions to tax for failure to make
deposit of taxes under section 6656.
OPINION
1. Underpayment Due to Negligence
Section 6653(a)(1)(A) (and section 6653(a)(1)) imposes an
addition to tax equal to 5 percent of the underpayment of tax if any
part of the underpayment is due to negligence or intentional
disregard of rules or regulations. Section 6653(a)(1)(B) provides
for an addition of 50 percent of the interest payable under section
6601 on the portion of the underpayment attributable to negligence
or intentional disregard of rules or regulations. Section 6662(a)
and (b)(1) imposes a penalty equal to 20 percent of the portion of
the underpayment that is attributable to negligence or disregard of
rules or regulations. Negligence includes a failure to make a
reasonable attempt to comply with the provisions of the Internal
Revenue laws or to exercise ordinary and reasonable care in the
preparation of a tax return. Sec. 6662(c). Negligence is a lack of
due care or failure to do what a reasonable and ordinarily prudent
person would do under the circumstances. Zmuda v. Commissioner, 731
F.2d 1417, 1422 (9th Cir. 1984), affg. 79 T.C. 714 (1982); Neely v.
Commissioner, 85 T.C. 934 (1985). The term "disregard" includes any
careless, reckless, or intentional disregard. Secs. 6653(a)(3),
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