Theodore Major Green and Jacqueline Green - Page 9
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Under sections 6662(a) and (b)(1), a taxpayer who has an
underpayment of tax may be liable for a penalty of 20 percent of
the underpayment of tax attributable to negligence or disregard
of the Federal income tax rules or regulations.
“[D]isregard of rules and regulations” includes careless,
reckless, or intentional disregard of rules and regulations.
Respondent bears the burden of proof in connection with the
section 6662(a) penalty. Rule 142(a). Respondent has met his
burden of proof.
In light of Mr. Green’s work as a tax auditor for respondent
and in light of the relatively straightforward adjustments we
sustain herein, we sustain respondent’s imposition of the $499
For the reasons stated, we shall grant respondent’s motion
for summary judgment.
An appropriate order and
decision will be entered for
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Last modified: November 10, 2007