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negligence 291,931”, followed by “Underpayment due to substantial
understatement 0”. As respondent has not amended his pleadings
to assert an underpayment due to substantial understatement, this
issue was not properly raised. In addition, we also observe that
the section 6664(c) reasonable cause exception is equally
applicable in the case of a section 6662(a) penalty attributed to
a substantial understatement of income tax. Respondent’s
determination of an accuracy-related penalty is denied.
To reflect the foregoing,
An appropriate order will
be issued, and decision will
be entered for respondent with
respect to the deficiency and
for petitioners with respect
to the accuracy-related
penalty.
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