Ferydoun Ahadpour, a.k.a, F. Ahadpour, And Doris Ahadpour - Page 29




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               Negligence includes a failure to make a reasonable attempt             
          to comply with the provisions of the internal revenue laws.  See            
          sec. 6662(c); sec. 1.6662-3(b)(1), Income Tax Regs.  Negligence             
          has also been defined as a lack of due care or failure to do what           
          a reasonable person would do under the circumstances.  See                  
          Norgaard v. Commissioner, 939 F.2d 874, 880 (9th Cir. 1991),                
          affg. in part and revg. in part on other grounds T.C. Memo. 1989-           
          390; Allen v. Commissioner, 925 F.2d 348, 353 (9th Cir. 1991),              
          affg. 92 T.C. 1 (1989).  “Disregard” includes any careless,                 
          reckless, or intentional disregard of rules or regulations.  See            
          sec. 6662(c); sec. 1.6662-3(b)(2), Income Tax Regs.                         
               There is a substantial understatement of income tax if the             
          amount of the understatement for the taxable year exceeds the               
          greater of (1) 10 percent of the tax required to be shown on the            
          return or (2) $5,000.  See sec. 6662(d)(1)(A).  For purposes of             
          section 6662(d)(1), “understatement” is defined as the excess of            
          tax required to be shown on the return over the amount of tax               
          that is shown on the return reduced by any rebate within the                
          meaning of section 6211(b)(2).  See sec. 6662(d)(2)(A).  Any                
          understatement is reduced by the portion of the understatement              
          attributable to an item for which there is substantial authority            
          for the treatment by the taxpayer or where the relevant facts               
          affecting the item’s tax treatment are adequately disclosed in              









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