Robert M. Johnson and Janna D. Begole, f.k.a. Janna D. Johnson - Page 12




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          respondent’s determination of the addition to tax for                       
          petitioners’ failure to timely file their 1993 Federal income tax           
          return.                                                                     
               Section 6662(a) imposes a penalty of 20 percent on                     
          underpayments of tax attributable to negligence or to disregard             
          of rules and regulations.  The definition of negligence includes            
          the failure by taxpayers to properly and adequately maintain                
          books and records.  Sec. 1.6662-3(b)(1), Income Tax Regs.                   
               We sustain respondent’s determination of the accuracy-                 
          related penalties for 1992 and 1993.                                        

                                             Decision will be entered for             
                                        respondent.                                   


























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