Theodore Major Green and Jacqueline Green - Page 9

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          Accuracy-Related Penalty                                                    
               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.                
          Sec. 6662(c).                                                               
               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              
          accuracy-related penalty.                                                   
               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