- 8 - less than the 40 percent or so that I was supposed to be paying. 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 Medico. 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. OPINION 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 NextLast modified: November 10, 2007