- 12 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
Last modified: May 25, 2011