Alex and Tonja Oria - Page 8
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less than the 40 percent or so that I was supposed to
The $32,580 Omission
During 2000, Mr. Oria failed to report $32,580 of personal
expenses charged on Medico’s American Express card and paid by
The $27,550 Omission
During 2000, Mr. Oria deposited receipts of Medico’s
totaling $194,888.57 into his personal bank account. Those
deposits were not entered in the general ledger and were not
reported on Medico’s 2000 Federal income tax return. Mr. Oria
paid certain expenses of Medico’s from his personal bank account;
the excess of deposits made over expenses paid during 2000 is
$27,550. Petitioners did not provide personal bank account
records to Mr. Loeser.
The $5,150 Omission
During 2000, Mr. Oria failed to report $5,150 of golf club
dues and other personal expenses paid by Medico.
Section 6662 imposes an accuracy-related penalty in the
amount of 20 percent of the portion of any underpayment
attributable to, among other things, negligence.2 Sec. 6662(a),
and (b)(1). Negligence has been defined as the failure to
exercise the due care of a reasonable and ordinarily prudent
person under like circumstances. Nis Family Trust v.
2 Respondent concedes any basis for a sec. 6662 penalty
other than negligence.
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Last modified: November 10, 2007