Rogelio R. Balot and Zenaida V. Balot - Page 40




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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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Last modified: May 25, 2011