Stephen D. Podd - Page 68

                                       - 68 -                                         
          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,         











Page:  Previous  52  53  54  55  56  57  58  59  60  61  62  63  64  65  66  67  68  69  70  71  Next

Last modified: May 25, 2011