What are the penalties for negligence under section 6651(a)(1) of the Tax Code?
MultiRegion, United States of America
The following excerpt is from Rakosi v. C.I.R., 46 F.3d 1144 (9th Cir. 1995):
Section 6651(a)(1) of the Tax Code imposes further penalties on a taxpayer when "any part of an underpayment of tax ... is due to negligence (or disregard of rules or regulations) ...." Negligence is here defined as a "lack of due care or failure to do what a reasonable and prudent person would do under similar circumstances." Allen v. C.I.R., 925 F.2d 348, 353 (9th Cir. 1991).
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