- 5 -- 5 -
Galuska v. Commissioner, 98 T.C. 661, 669-670 (1992), affd. 5
F.3d 195 (7th Cir. 1993).
There is no evidence that petitioner's application for an
additional extension of time to file his return was ever
approved. Furthermore, the phrase "tax practitioner's workload"
standing alone on the application does not show reasonable cause
for the additional delay. Thus, petitioner's return was due to
be filed by August 15, 1995, and the addition to tax is
calculated from that date. We sustain the addition to tax under
section 6651(a)(1).
Section 6662(a)
Section 6662(a) imposes a penalty of 20 percent on any
portion of an underpayment of tax that is attributable to
negligence or disregard of rules or regulations. Sec. 6662(a)
and (b)(1). Negligence in this context includes any failure to
make a reasonable attempt to comply with the provisions of the
Internal Revenue Code, and the term "disregard" includes any
careless, reckless, or intentional disregard. Sec. 6662(c).
The accuracy-related penalty does not apply if petitioner
demonstrates that there was reasonable cause for the underpayment
and that he acted in good faith with respect thereto. Sec.
6664(c). Whether a taxpayer acted with reasonable cause and in
good faith depends upon the pertinent facts and circumstances.
McCallson v. Commissioner, T.C. Memo. 1993-528; sec. 1.6664-
4(b)(1), Income Tax Regs. The most important factor is the
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