-19- to cancel their business relationship. Thus, Gump differs from this case. We conclude that Mr. and Mrs. Fox are liable for self- employment tax of $10,658 for 1992 and $11,057 for 1993. F. Whether Mr. and Mrs. Fox Are Liable for the Addition to Tax for Failure To File for 1993 and the Accuracy-Related Penalty for 1989, 1992, and 1993 Respondent determined and contends that Mr. and Mrs. Fox are liable for the addition to tax for failure to file an income tax return for 1993 under section 6651(a) and the accuracy-related penalty for 1989, 1992, and 1993 under section 6662(a) for negligence. 1. Section 6651(a)(1) A taxpayer is liable for an addition to tax of up to 25 percent for failure to file timely Federal income tax returns unless the taxpayer shows that such failure was due to reasonable cause and not willful neglect. Sec. 6651(a)(1); United States v. Boyle, 469 U.S. 241, 245 (1985); Davis v. Commissioner, 81 T.C. 806, 820 (1983), affd. without published opinion 767 F.2d 931 (9th Cir. 1985). 2. Section 6662(a) Taxpayers are liable for a penalty under section 6662 equal to 20 percent of the part of the underpayment which is attributable to negligence. Sec. 6662(a). For purposes of section 6662(a), negligence is a failure to reasonably attempt to comply with the Internal Revenue Code. Sec. 6662(c). ThePage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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