- 6 - Cancellation of Indebtedness Income Gross income includes income from the cancellation of indebtedness. Sec. 61(a)(12). Respondent contends that petitioner had cancellation of indebtedness income of $2,136 from American Express. Petitioner claims that there was no cancellation of debt because the debt was already paid. He contends that American Express made a miscalculation, implying that the cancellation was actually a correction to his account. Petitioner, however, failed to offer any evidence to show that the debt was paid. There is also no evidence that any of the exclusions under section 108(a)(1) applies. Therefore, petitioner had cancellation of indebtedness income of $2,136 in 2003. Section 6662(a) Accuracy-Related Penalty Respondent determined that petitioner is liable for an accuracy-related penalty under section 6662(a). Section 6662(a) imposes a 20-percent penalty on the portion of an underpayment attributable to any one of various factors, including negligence or disregard of rules or regulations and a substantial understatement of income tax. See sec. 6662(b)(1) and (2). “Negligence” includes any failure to make a reasonable attempt to comply with the provisions of the Internal Revenue Code, including any failure to keep adequate books and records or toPage: Previous 1 2 3 4 5 6 7 8 9 10 NextLast modified: November 10, 2007