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Document, titled "Gross Receipts", lists compensation income of
$79,914. Schedule B of the Document, titled "Expenditures",
lists Federal and State withholding taxes in the respective
amounts of $4,844 and $1,078, Social Security taxes paid in the
amount of $3,856, and child care expenses of $4,800. On the
final page, petitioners make a demand for restitution from the
United States for all taxes paid less all sums owed. Petitioners
submitted Forms W-2 with the Document. Petitioners never filed a
return for their 1995 taxable year on Form 1040.
The IRS did not process the Document as a return because it
did not include sufficient information.
Respondent mailed the notice of deficiency on April 16,
1998.
OPINION
Respondent determined that petitioners were liable for the
accuracy-related penalty under section 6662(a) in the amount of
$2,225. Section 6662(a) imposes an accuracy-related penalty of
20 percent on any portion of an underpayment of tax that is
attributable to items set forth in section 6662(b). Section
6662(b)(1) applies section 6662(a) to any portion of an
underpayment attributable to negligence or disregard of rules or
regulations.
However, the accuracy-related penalty under section 6662(a)
may only be imposed "in cases where a return of tax is filed
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