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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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