Terry F. and Carol J. Zdun - Page 22

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          Issue 2.  Accuracy-Related Penalty Under Section 6662                       
               Respondent determined that petitioners are liable for                  
          accuracy-related penalties pursuant to section 6662 of $1,334,              
          $1,937, and $2,004 for 1992, 1993, and 1994, respectively.                  
          Respondent asserts that the section 6662(a) penalty in each year            
          is due to a substantial understatement of tax.  See sec.                    
          6662(b)(2).  Petitioners assert that they are not liable for the            
          section 6662(a) penalty, because they reported all of their                 
          income and the correct amount of tax for each of the years at               
          issue.                                                                      
               Section 6662(a) imposes a penalty in an amount equal to 20             
          percent of the portion of the underpayment of tax attributable to           
          one or more of the items set forth in subsection (b).  Section              
          6662(b)(2) provides that section 6662 shall apply to any portion            
          of the underpayment attributable to any substantial                         
          understatement of income tax.  There is a substantial                       
          understatement of income tax if the amount of the understatement            
          for the taxable year exceeds the greater of (1) 10 percent of the           
          tax required to be shown on the return, or (2) $5,000.  Sec.                
          6662(d)(1)(A).  For purposes of section 6662(d)(1),                         
          "understatement" is defined as the excess of tax required to be             
          shown on the return over the amount of tax that is shown on the             
          return reduced by any rebate.  Sec. 6662(d)(2)(A).                          







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