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required to be shown on the return for the taxable year over the
amount of tax shown on the return for the taxable year reduced by
any rebate. Secs. 6661(b)(2), 6662(d)(2)(A). In calculating
understatements, items for which there was substantial authority or
adequate disclosure are not to be considered. Secs.
6661(b)(2)(B)(i) and (ii), 6662(d)(2)(B)(i) and (ii).
3. Failure To File Tax Return
Section 6651(a)(1) provides for an addition to tax of 5 percent
of the tax required to be shown on the return for each month or
fraction thereof for which there is a failure to file, not to exceed
25 percent. The addition to tax for failure to file a return timely
will be imposed if a return is not timely filed unless the taxpayer
shows that the delay was due to reasonable cause and not willful
neglect. Sec. 6651(a)(1).
4. Failure To Make Deposit of Taxes
Section 6656(a) imposes an addition to tax for failure to
deposit timely a tax in a Government depositary, unless it is shown
that such failure was due to reasonable cause and not due to willful
neglect. For additions to tax assessed after October 21, 1986, the
amount of the addition is 10 percent of the underpayment. Sec.
6656(a). For deposits required to be made after December 31, 1989,
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