Virginia A. Fox, et al. - Page 7




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          Willful neglect means a conscious, intentional failure or                   
          reckless indifference.  United States v. Boyle, supra at 245.               
          Petitioners have presented no persuasive evidence on this issue,            
          and the record does not otherwise establish that their failure to           
          file timely returns was due to reasonable cause and not due to              
          willful neglect.  We sustain respondent’s determinations under              
          section 6651(a).                                                            
               As to respondent’s determinations under section 6654,                  
          section 6654(a) provides for an addition to tax "in the case of             
          any underpayment of estimated tax by an individual".  Generally,            
          this addition to tax is mandatory, and there is no exception for            
          reasonable cause.  Recklitis v. Commissioner, 91 T.C. 874, 913              
          (1988); Grosshandler v. Commissioner, 75 T.C. 1, 20-21 (1980).              
          However, no addition to tax is imposed if one of the exceptions             
          contained in section 6654 is met.  Recklitis v. Commissioner,               
          supra at 913.  Petitioners have offered no evidence to show that            
          any of the statutory exceptions apply.  We sustain respondent’s             
          determinations under section 6654(a).                                       
               As to respondent’s determination under section 6662(a),                
          section 6662(a) and (b)(1) imposes a 20-percent accuracy-related            
          penalty on the portion of an underpayment that is due to                    
          negligence or intentional disregard of rules or regulations.                
          Negligence includes a failure to attempt reasonably to comply               
          with the Code.  See sec. 6662(c).  Disregard includes a careless,           







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