Haffner's Service Stations, Inc. - Page 52




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          by petitioner for a contrary holding as to this issue.  We also             
          disagree with petitioner’s reading of the above quoted provision            
          of its articles of incorporation to impose upon its board a short           
          time to redeem a shareholder’s stock should the board desire to             
          do so.  We read nothing in the quoted provision that sets a time            
          limitation on the board’s ability to redeem stock.                          
          3.  Accuracy-Related Penalties                                              
               Respondent determined that petitioner was liable for                   
          accuracy-related penalties under section 6662(a) and (b)(1) for             
          negligence or intentional disregard of rules and regulations.               
          Petitioner argues that it is not liable for these penalties                 
          because it relied reasonably on its accountants’ advice in                  
          preparing its returns.  We agree with petitioner.                           
               As relevant herein, 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.  Sec. 6662(c).                  
          Disregard includes a careless, reckless, or intentional                     
          disregard.  Id.                                                             
               A section 6662(a) accuracy-related penalty shall not be                
          imposed to the extent that the taxpayer shows that an                       
          underpayment is due to the taxpayer’s having reasonable cause and           
          acting in good faith.  Sec. 6664(c); secs. 1.6662-3(a),                     
          1.6664-4(a), Income Tax Regs.  Reasonable cause requires that the           
          taxpayer have exercised ordinary business care and prudence as to           





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