Legal Opinion

Snow v. Commissioner

United States Tax Court

Decided September 19, 2013No. Docket No. 24783-09PublishedCited by 2 opinions

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 were not addressed in Feller.

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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 were not addressed in Feller. Held: Respondent properly computed petitioner's underpayment for purposes of I.R.C. sec. 6662(a).

1Opinion of the Court

SUPPLEMENTAL FINDINGS OF FACT AND OPINION

Ruwe, Judge:

This matter is before the Court as a result of the parties’ dispute over the proper computations for entry of decision under Rule 155 1 in connection with our Memorandum Findings of Fact and Opinion in Snow v. Commissioner, T.C. Memo. 2013 — 114. In Snow v. Commissioner, at *5, we held that wages petitioner received as compensation for his work as a musician were includable in his income. Additionally, we held that petitioner was liable for the accuracy-related penalty under section 6662(a) due to negligence and a substantial understatement…

2Cases cited1 opinion

  1. Feller v. CommissionerUnited States Tax Court · 2010

3Cited by2 opinions

  1. Galloway v. Comm'rUnited States Tax Court · 2017
  2. Glenn Lee Snow v. CommissionerUnited States Tax Court · 2013

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