- 19 - was not entitled to head of household filing status was reasonable. Accuracy-Related Penalty Under Section 6662 Section 6662 imposes a penalty equal to 20 percent of the portion of the underpayment of tax attributable to negligence or disregard of rules or regulations. See sec. 6662(a) and (b)(1). Negligence is defined as any failure to make a reasonable attempt to comply with the provisions of the Internal Revenue Code, and the term "disregard" includes any careless, reckless, or intentional disregard. See sec. 6662(c). Petitioner has not disputed the legal standard applied by respondent here but disputes only whether respondent had a reasonable factual basis to believe that the legal standard applied to him. This case is primarily one of substantiation. When respondent issued the statutory notice of deficiency and filed the answer in this case, petitioner had not substantiated deductions for charitable contributions, home mortgage interest, and dependency exemptions. Indeed, although respondent has settled the issues in this case, petitioner has yet provided only indirect or inferential evidence for most of the issues involved here. We conclude that the position of respondent had a reasonable basis in fact based on the information produced during the examination in this case before trial.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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