- 10 - receivable accounts was not verified and further does not constitute a bona fide debt. Accordingly, petitioner is not entitled to the partnership loss deduction during the years in issue. Respondent is sustained on this issue. Accuracy-Related Penalty Section 6662(a) imposes an accuracy-related penalty of 20 percent of the portion of the underpayment which is attributable to negligence or disregard of rules or regulations. Sec. 6662(b)(1). Negligence is the lack of due care or failure to do what a reasonable and ordinarily prudent person would do under the circumstances. Neely v. Commissioner, 85 T.C. 934, 947 (1985). The term “disregard” includes any careless, reckless, or intentional disregard. Sec. 6662(c). No penalty shall be imposed if it is shown that there was reasonable cause for the underpayment and the taxpayer acted in good faith with respect to the underpayment. Sec. 6664(c). On the basis of the record, we find that petitioner has failed to demonstrate that he was not negligent and did not disregard rules or regulations. We hold that petitioner is liable for the accuracy-related penalty under section 6662(a) for each year in issue. We have considered all arguments by the parties, and, to the extent not discussed above, conclude that they are irrelevant or without merit.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011