- 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