- 22 - 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).Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
Last modified: May 25, 2011