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the section 6662(a) accuracy-related penalty on underpayment of
tax, since there was no underpayment of tax. Even though
petitioner admitted that her income tax return for 2001 was not
filed timely, she, nonetheless, is not liable for the section
6651(a)(1) addition to tax because the addition to tax is based
on a percentage of the tax “required to be shown on the return”.
Since the Court holds that petitioner had no tax liability, it
follows that petitioner is not liable for the section 6651(a)(1)
addition to tax.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
+ for petitioner.
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Last modified: May 25, 2011