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6662(b)(1). Negligence is any failure to make a reasonable
attempt to comply with the provisions of the internal revenue
laws. Sec. 6662(c); sec. 1.6662-3(b)(1), Income Tax Regs.
Moreover, negligence has been described as the failure to
exercise due care or the failure to do what a reasonable and
prudent person would do under the circumstances. Neely v.
Commissioner, 85 T.C. 934, 947 (1985). Disregard includes any
careless, reckless, or intentional disregard of rules or
regulations. Sec. 6662(c); sec. 1.6662-3(b)(2), Income Tax Regs.
Section 7491(c) requires respondent to carry the burden of
production because he seeks to impose an accuracy-related penalty
pursuant to section 6662(a). With respect to the returns for
1996 and 1997, respondent and petitioner stipulated that
petitioner attempted to file those returns “as joint returns by
signing his former spouse’s name as well as his own name”,
thereby claiming an additional exemption and calculating the
income tax under the more favorable rates of section 1(a)(1).
The parties also stipulated that interest income and income from
the sale of stocks were omitted from the 1996 and 1997 returns.
The 2000 return petitioner filed reported zero on all income
entries and no taxable income even though respondent and
petitioner stipulated that petitioner received $3,209 in 2000
from the sale of stock, $17 interest on an account with National
Financial Services Co., and $36,591 as wages from the U.S. Postal
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