Evelyn J. Glenn - Page 19




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           using our best judgment, but bearing heavily against petitioner            
           whose inexactitude is of her own making, we hold that                      
           petitioner is entitled to deduct telephone expense in the                  
           amount of $1,000 for each of the years in issue.  See Cohan v.             
           Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930).                         
           F. Accuracy-Related Penalties                                              
                Finally, we turn to respondent's determination that                   
           petitioner is liable for accuracy-related penalties under                  
           section 6662(a).                                                           
                Section 6662(a) imposes an accuracy-related penalty equal             
           to 20 percent of the underpayment of tax resulting from, inter             
           alia, negligence or disregard of rules or regulations.  See                
           sec. 6662(b)(1).  For purposes of section 6662(a), the term                
           "negligence" includes any failure to make a reasonable attempt             
           to comply with the Code, and the term "disregard" includes any             
           careless, reckless, or intentional disregard.  Sec. 6662(c).               
           Negligence has also been defined as a lack of due care or                  
           failure to do what a reasonable person would do under the                  
           circumstances.  See Antonides v. Commissioner, 91 T.C. 686, 699            
           (1988), affd. 893 F.2d 656 (4th Cir. 1990).                                
                The accuracy-related penalty under section 6662(a) does               
           not apply 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.  See sec. 6664(c)(1).  The                   






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