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amount equal to 20 percent of the portion of the underpayment to
which section 6662 applies. Section 6662(b)(1) provides that
section 6662 shall apply to any underpayment attributable to
negligence or disregard of rules or regulations.
Section 6662(c) provides that the term "negligence" includes
any failure to make a reasonable attempt to comply with the
provisions of the internal revenue laws, and the term "disregard"
includes any careless, reckless, or intentional disregard of
rules or regulations. Negligence is the lack of due care or
failure to do what a reasonable and ordinarily prudent person
would do under the circumstances. See Neely v. Commissioner, 85
T.C. 934, 947 (1985).
However, under section 6664(c), no penalty shall be imposed
under section 6662(a) with respect to any portion of an
underpayment if it is shown that there was a reasonable cause for
such portion and that the taxpayer acted in good faith with
respect to such portion. The determination of whether a taxpayer
acted with reasonable cause and in good faith depends upon the
facts and circumstances of each particular case. See sec.
1.6664-4(b)(1), Income Tax Regs. Relevant factors include the
taxpayer's efforts to assess his or her proper tax liability, the
knowledge and experience of the taxpayer, and reliance on the
advice of a professional, such as an accountant. See Drummond v.
Commissioner, T.C. Memo. 1997-71, affd. in part, revd. in part
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