Robert Fedewa - Page 11




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          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.                                                              






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