Sherif S. Abdelhak a.k.a. Samuel A. Abel - Page 15

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          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 for             






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