Henry F. K. Kersting - Page 18




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          percent of the underpayment if any part of the underpayment is              
          attributable to negligence.  Section 6653(a)(2) also imposes                
          an addition to tax equal to 50 percent of the interest payable on           
          the portion of the underpayment attributable to negligence.                 
               With respect to returns that have due dates after December             
          31, 1986 (e.g., petitioner's 1986 and 1987 tax returns), section            
          1503(a) of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat.            
          2085, 2742-2743, replaced former section 6653(a)(1) and (2) with            
          section 6653(a)(1)(A) and (B).  Section 6653(a)(1)(A)                       
          and (B) is similar to former section 6653(a)(1) and (2).  Section           
          6653(a)(1)(A) imposes an addition to tax equal to 5 percent of              
          the underpayment if any part of the underpayment is attributable            
          to negligence.  Section 6653(a)(1)(B) imposes an addition to tax            
          equal to 50 percent of the interest payable on the portion of the           
          underpayment attributable to negligence.                                    
               With respect to returns that have due dates after December             
          31, 1988 (e.g., petitioner's 1988 tax return), section                      
          1015(b)(2)(A) of the Technical and Miscellaneous Revenue Act of             
          1988 (TAMRA), Pub. L. 100-647, 102 Stat. 3342, 3569, replaced               
          former section 6653(a)(1)(A) and (B) with section 6653(a).                  
          Section 6653(a) was similar to former section 6653(a)(1)(A).                
          Section 6653(a) imposes an addition to tax equal to 5 percent of            
          the portion of the underpayment attributable to negligence.                 
          Section 6653(a)(1)(B), however, has no counterpart                          





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