- 40 - Section 666215 imposes an accuracy-related penalty of 20 15Sec. 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 [part II, relating to accuracy-related and fraud penalties] with respect to any portion of an underpayment if it is shown that there was reasonable cause for such portion and that the taxpayer acted in good faith with respect to such portion.Page: Previous 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 Next
Last modified: May 25, 2011