The negligence penalty also applies to any understatement
caused by a careless, reckless, or intentional disregard of a specific provision of the IRC, Treasury Regulations, a revenue ruling, or an IRS notice.
For example, if a portion of an underpayment of tax is attributable to both a substantial understatement
and a gross valuation misstatement, the maximum accuracy-related penalty is 40% of the underpayment, rather than a combined 60%.
For C corporations, substantial understatement
is defined as the lesser of 10 percent of the lax, as adjusted (or, if greater, $10,000), or $10 million.
(29) This penalty, however, may also be imposed with respect to any taxable year for which the statute of limitations has not expired as of January 1, 2005, when such understatement
is attributable to a listed transaction which was entered into after February 28, 2000, and before December 31, 2004.
As a result, the auditor worked to eliminate the understatement
. However, in order to stay within the budget as planned, the auditor let the overstatement drift as high as possible based on the level considered tolerable by professional standards for a type II error.
You must establish that at the time you signed the joint return, you did not know, and had no reason to know, that there was an understatement
"Provocative" seems an understatement
for a speculative new report suggesting that early treatment with zidovudine (AZT) or similar antiviral agents, while benefiting infected individuals, might indirectly increase both the number of infections and the daily death toll from AIDS in certain population groups.
As noted in the sidebar, I believe MUS is a relatively easy and highly efficient tool to use when testing for overstatement, and this is often the principal audit concern; however, "principal" does not mean "exclusive," and so auditors must think about assertions where understatement
may be as significant a concern as overstatement.
6662 imposes an accuracy-related penalty equal to 20% of any underpayment of federal tax resulting from certain specified taxpayer behaviors (e.g., negligence, disregard of rules or regulations, substantial understatement
of income tax, and certain over-and undervaluations).
California's noneconomic substance transaction understatement
(NKST) penalty imposes a 20 percent penalty for understatements
attributable to noneconomic substance transactions (CA Rev.
To say that Chun Hyang, the 14-year-old heroine of The Legend of Chun Hyang, is a strong female character would be an understatement
. Employing a martial arts style that would make a whirling dervish proud, she fights the good fight against the corrupt Yang Ban (ruler) of her town.
The jury was impressed with the simpllicity, competence and understatement
of this quiet addition to a treasured cityscape.
New section 6662A provides a more stringent set of accuracy-related penalty rules for RTs--increasing the ante from 20 percent to 30 percent for undisclosed LTs and "reportable avoidance transactions" (RATs); and more expansively calculating the "understatement
" against which the penalty is applied.
It was to be hot at a time when cool was in, to indulge authenticity and overstatement when understatement
and irony were fashionable.
In any case, the remedy is apportioned relief for the part of the tax understatement
about which the taxpayer has no knowledge or reason to know.