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Section 66625 imposes an accuracy-related penalty of 20
percent of any portion of an underpayment that is attributable to
the taxpayer’s negligence. Subsecs. (a) and (b)(1) of sec. 6662.
5 Sec. 6662 provides, in pertinent part, as follows:
SEC. 6662. IMPOSITION OF ACCURACY-RELATED PENALTY.
(a) Imposition of Penalty.--If this section applies to any
portion of an underpayment of tax required to be shown on a
return, there shall be added to the tax an amount equal to 20
percent of the portion of the underpayment to which this section
applies.
(b) Portion of Underpayment to Which Section Applies.--This
section shall apply to the portion of any underpayment which is
attributable to 1 or more of the following:
(1) Negligence or disregard of rules or regulations.
* * * * * * *
(c) Negligence.--For purposes of this section, the term
“negligence” includes any failure to make a reasonable attempt to
comply with the provisions of this title, [title 26, the Internal
Revenue Code] and the term “disregard” includes any careless,
reckless, or intentional disregard.
Sec. 6664 provides, in pertinent part, as follows:
SEC. 6664. DEFINITIONS AND SPECIAL RULES.
* * * * * * *
(c) Reasonable Cause Exception.--
(1) In general.--No penalty shall be imposed under
this part 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.
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