Debo Joel Ogungbade - Page 9

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          any careless, reckless, or intentional disregard.”  Sec. 6662(c).           
          “Negligence” also includes any failure by a taxpayer to keep                
          adequate books and records or to substantiate items properly.               
          Sec. 1.6662-3(b), Income Tax Regs.                                          
               Section 6662(d)(1)(A) provides that there is a substantial             
          understatement of income tax for any taxable year if the amount             
          of the understatement for the taxable year exceeds the greater              
          of:  (1) 10 percent of the tax required to be shown on the return           
          for the taxable year, or (2) $5,000.  The term “understatement”             
          means the amount of tax required to be shown on the return for              
          the taxable year, over the amount of tax imposed which is shown             
          on the return, reduced by any rebate.  Sec. 6662(d)(2)(A).  All             
          of the adjustments determined in the notice of deficiency have              
          been conceded or sustained.  Petitioner’s return reported a tax             
          of $1,046.  The amount of the deficiency is $6,225.                         
               An accuracy-related penalty is not imposed with respect to             
          any portion of the underpayment as to which the taxpayer acted              
          with reasonable cause and in good faith.  Sec. 6664(c)(1); see              
          Higbee v. Commissioner, 116 T.C. 438, 448 (2001).  This                     
          determination is made based on all the relevant facts and                   
          circumstances.  Higbee v. Commissioner, supra at 448; sec.                  
          1.6664-4(b)(1), Income Tax Regs.  “Relevant factors include the             








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