Frank K. B. Wheeler - Page 29




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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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Last modified: May 25, 2011