- 10 - Petitioners claim that they provided complete and timely information to their C.P.A. and that it was the C.P.A. who did not timely file the income tax returns. Petitioner, a practicing lawyer, was fully capable of making sure that the income tax returns for himself, his wife, and his firm were completed and filed on time. Petitioner’s alleged reliance on the C.P.A. is not credible. Petitioners are liable for the additions to tax under section 6651(a)(1) for the failure to timely file their income tax returns for the years in issue. Section 6662 Accuracy-Related Penalties Section 6662 imposes an accuracy-related penalty of 20 percent on underpayments of tax attributable to: (1) Negligence or to disregard of the rules or the regulations; and (2) substantial understatements of income tax. Section 6662(d)(1) defines “substantial understatements” as the greater of: (1) More than 10 percent of the tax required to be shown on the tax return; or (2) $5,000 in the case of an individual, and $10,000 in the case of a corporation. The section 6662 accuracy-related penalty is not imposed with respect to portions of underpayments of tax for which taxpayers acted with reasonable cause and in good faith. See sec. 6664(c)(1). The decision as to whether taxpayers acted with reasonable cause and in good faith depends upon all the pertinentPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011