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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.
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