Marie-Francine T. Grow - Page 7

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          Unreported Income                                                           
               Respondent’s determination of additional Schedule C income             
          of $1,597 is based on third-party information submitted on Forms            
          1099-MISC.  Petitioner does not dispute that her former husband             
          may have received the income reported.  We sustain respondent’s             
          determination with respect to this issue.                                   
          Penalty Under Section 6662(a)                                               
               Relevant here, section 6662(a) imposes a penalty in the                
          amount of 20 percent of the underpayment due, inter alia, to                
          negligence or to a substantial understatement of tax.  Neither in           
          the notice of deficiency nor at trial did respondent specify                
          which ground applied here.  We do not find that the negligence              
          penalty is appropriate here with regard to this petitioner, and             
          therefore, we focus on whether there was a substantial                      
          understatement.  A substantial understatement is defined, inter             
          alia, as an understatement of tax that exceeds 10 percent of the            
          tax required to be shown on the return.  Sec. 6662(d)(1)(A)(i).             
          The understatement here exceeds 10 percent of the tax required to           
          be shown on the return.  See sec. 6662(d)(2).  Petitioner has not           
          shown that any of the circumstances contained in section                    
          6662(d)(2)(B) apply.                                                        
          Innocent Spouse Relief                                                      
               A requesting spouse may elect relief from joint and several            
          liability under section 6015.  There are three types of relief              






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