- 28 - petitioner was availed of for the purpose of evading the income tax on shareholders and is limited to accumulating, without imposition of accumulated earnings tax, no more than $250,000. III. Whether Petitioner Is Liable for Accuracy-Related Penalties Under Section 6662(a) for 1995 and/or 1996 Section 6662(a) imposes an accuracy-related penalty if any portion of an underpayment is attributable to negligence or disregard of rules or regulations or any substantial understatement of tax. A substantial understatement for a corporation is an understatement that exceeds the greater of 10 percent of the tax required to be shown on the return or $10,000. For 1995 and 1996, petitioner’s understatement may exceed the 10- percent or $10,000 threshold. The penalty will not apply to any portion of an underpayment for which there was reasonable cause for the position taken and the taxpayer acted in good faith. See sec. 6664(c). Respondent, focusing on the reasonable compensation question, contends that the Valentes did little or nothing to earn the $240,435 and $460,000 salaries they were paid. Although we have concluded that the value of their services was less than 8(...continued) matters, no steps had been taken or evidence presented that corroborated these matters as established or reasonable needs.Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
Last modified: May 25, 2011