Ronald C. McKee and Anita L. McKee - Page 6

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          tax for 2001 based on petitioners’ failure to report on their               
          return for that year wages received by Mr. McKee from Autocar in            
          the amount of $13,775.  In a Stipulation of Settled Issues,                 
          petitioners conceded that they are liable for the deficiency in             
          income tax as determined by respondent.                                     
               Respondent also determined an accuracy-related penalty under           
          section 6662(a) based on petitioners’ failure to report the                 
          aforementioned wages.  In this regard, respondent determined that           
          the underpayment is attributable to (1) negligence or disregard             
          of rules or regulations and/or (2) a substantial understatement             
          of tax.                                                                     
          Discussion                                                                  
          A.   Substantive Law                                                        
               Section 6662(a) imposes a penalty equal to 20 percent of any           
          underpayment of tax that is attributable to either (1) negligence           
          or disregard of rules or regulations or (2) a substantial                   
          understatement of income tax.  See sec. 6662(a), (b)(1) and (2).            
               The term “negligence” includes any failure to make a                   
          reasonable attempt to comply with the Internal Revenue Code.                
          Sec. 6662(c).  The term “disregard” includes any careless,                  
          reckless, or intentional disregard.  Id.; sec. 1.6662-3(b)(2),              
          Income Tax Regs.                                                            
               An understatement of income tax is “substantial” if it                 
          exceeds the greater of 10 percent of the tax required to be shown           






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