Glenn Lee Snow v. Commissioner

141 T.C. No. 6

UNITED STATES TAX COURT GLENN LEE SNOW, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent* Docket No. 24783-09. Filed September 19, 2013. The issue before us concerns a dispute over the Rule 155 computation of the “underpayment” for purposes of applying the I.R.C. sec. 6662(a) accuracy-related penalty. In Feller v. Commissioner,

135 T.C. 497

(2010), we held that sec. 1.6664-2(c)(1), Income Tax Regs., was valid. This Opinion follows Feller and applies and explains the other provisions of sec. 1.6664-2, Income Tax Regs., for determining the amount of an “underpayment” that…