- 15 - existed for his late filing. Petitioner claims constant transit and relocations as his reasonable cause for late filing. We are not convinced by this argument. Thus, with no evidence probative of reasonable cause, we conclude that petitioner is liable under section 6651(a)(1) for additions to tax for failure to timely file his Federal income tax returns for 1998, 1999, and 2000. VI. Accuracy-Related Penalties Respondent also determined that petitioner is liable under section 6662(a) for accuracy-related penalties for tax years 1998 and 1999. Section 6662(a) imposes an accuracy-related penalty equal to 20 percent of the underpayment to which section 6662 applies. Section 6662 applies to the portion of an underpayment of tax which is attributable to, among other things, negligence or intentional disregard of rules or regulations, a substantial understatement of income tax, or a substantial valuation misstatement. See sec. 6662(b)(1)-(3). Section 6662(c) defines “negligence” as “any careless, reckless, or intentional disregard.” See also Hansen v. Commissioner, 820 F.2d 1464, 1469 (9th Cir. 1987) (“Intentional disregard occurs when a taxpayer who knows or should know of a rule or regulation chooses to ignore the requirements.”). Section 6664(c)(1) provides that the accuracy-related penalty shall not be imposed with respect to any portion of an underpayment if it is shown that there was reasonable cause forPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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