Allen and Mary Doxtator - Page 32

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          have failed to substantiate casualty losses greater than the                
          amounts conceded by respondent, and we sustain that portion of              
          respondent's determination that has not been conceded.                      
          Accuracy-Related Penalties                                                  
               Respondent determined that petitioners were liable for the             
          accuracy-related penalty based on a substantial understatement of           
          income tax, or alternatively, negligence or disregard of rules or           
          regulations, for 1997 and 1999.  Sec. 6662(a) and (b)(1) and (2).           
          Respondent also determined that petitioners were liable for the             
          accuracy-related penalty based on negligence or disregard of                
          rules or regulations for 2000.  Sec. 6662(a) and (b)(1).                    
               A "substantial understatement" exists for this purpose if              
          the amount of tax required to be shown on the return exceeds that           
          shown by the greater of 10 percent of the tax required to be                
          shown or $5,000.  Sec. 6662(d).  "Negligence" for purposes of               
          section 6662 includes any failure to make a reasonable attempt to           
          comply with the provisions of the internal revenue laws or to               
          exercise ordinary and reasonable care in the preparation of a tax           
          return.  Sec. 6662(c); sec. 1.6662-3(b)(1), Income Tax Regs.                
               Only one accuracy-related penalty may be imposed with                  
          respect to any given portion of an underpayment, even if that               
          portion is attributable to more than one of the types of                    
          misconduct listed in section 6662(b).  Jaroff v. Commissioner,              
          T.C. Memo. 2004-276; sec. 1.6662-2(c), Income Tax Regs.                     






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