 known the amount they were ahead or behind, but they chose not do so and did not require their bookkeeper to do so, even though she, in the initial stages, had done so. Petitioners are required to report, as income, the amount of the excess in their check exchanges with M&L.
Respondent also determined that petitioners are liable for substantial understatement penalties under section 6662. Petitioners bear the burden to show they are not liable for the penalty. Rule 142(a); Bixby v. Commissioner [Dec. 31,493], 58 T.C. 757, 791-792 (1972). Section 6662 imposes the penalty on any portion of an underpayment of tax required to be shown on a return if, as pertinent here, there is any substantial understatement of income tax. Sec. 6662(b)(2). A substantial understatement exists if the amount of the understatement for the taxable year exceeds the greater of 10 percent of the amount of tax required to be shown on the return or $5,000. Sec. 6662(d)(1). A substantial understatement may be reduced for any item reported for which there was substantial authority or for which there was adequate disclosure of the facts. Sec. 6662(d)(2)(B). Substantial authority requires a showing that the weight of authorities supporting a taxpayer's position is substantial in relation to those supporting a contrary view. Antonides v. Commissioner [Dec. 45,094], 91 T.C. 686, 702 (1988), affd. [90-1 USTC ╤ 50,029] 893 F.2d 656 (4th Cir. 1990). In addition, no penalty will be applied to any portion of an underpayment if there was a reasonable cause for such portion and the taxpayer acted in good faith. Sec. 6664(c)(1).
Petitioners argue that they should not be liable for the penalty because "They held a good faith belief that the check exchange did not involve income to them." The facts of this case belie any claim of good faith on petitioners' part. Their bookkeeper/tax return preparer advised petitioners that any excess in their favor at the end of the year was taxable income. Also, petitioners failed to report any of the interest and/or broker fees either paid or credited to them by M&L. Finally, petitioners did not keep adequate books and records, and the bank deposits analysis shows a substantial understatement of income. Accordingly, we hold that the entire underpayment is subject to the section 6662 penalty.
To reflect the foregoing,
Decision will be entered for respondent.
КомментарииGreat success at the Kensington Fall Festival! Thanks everyone who stopped by for a friendly chat and to all those new customers who took my handcrafted infinity scarves and pillows home with them. Spreading my creative joy feels great! If you missed it, stop at GALA - Artisan Jewelry and Gifts and check out my designs there!Did you know that human errors cause between 75% to 96% of marine accidents?
Every day, maritime workers risk their lives. Sailors confront the risk of injuries and accidents due to their vessel’s conditions or the weather while at sea.
While no company can control the weather, they can ensure the safety of their employees on board sea vessels. In addition, the Jones Act laws protect injured seamen, allowing them to get compensation and benefits.
Often, injuries and accidents occur suddenly out of nowhere, sometimes leaving terrible consequences in their wake.
If you’re a seaman and hurt while working on a ship, you may be entitled to file a Jones Act claim to recover damages. Learn more about the Jones Act below.
This maritime law is known as the Jones Act. It is a federal law that gives injured sailors who have been injured while at sea a form of compensation. In addition, they can sue their employer for a personal injury claim.
Crew members are not eligible for workers’ compensation benefits in either state or federal law, in contrast to other land-based employees who are. Injured sailors are only entitled to compensation under the Jones Act and ordinary maritime law.
Those who have been hurt or killed at sea due to carelessness or unseaworthiness may file a Jones Act action against their employer.
What Does the Jones Act Define as Negligence?
A sailor’s employer is required by the Jones Act to provide a sufficiently safe working environment for the sailor. In addition, the employer shall take reasonable care to maintain and preserve the vessel on which the sailor works in a fairly safe condition given the circumstances.
There are, of course, many other hazards that can happen. All these place a big burden on the employer to make sure the workplace is safe and secure.
Do You Need to Hire a Lawyer and What Steps to Take?
In general, it is a step in the right direction to hire a Jones Act lawyer. They are experienced and know the ropes.
First, you should know that providing a recorded statement is not mandated by law.
Some vessel owners may put their own interests ahead of their employees’ by putting pressure on the injured to provide such a statement. Sadly, sailors frequently comply, believing they are helpful.
Providing a recorded statement may actually harm your Jones Act claim. So, respectfully refuse and contact your lawyer before pursuing the matter.
Similarly to the above, you are not required to fill out accident reports immediately. However, there are benefits to filling out an accident report if you’ve been injured. A sailor has three years to bring a claim to court.
You may do a few things if you have a Jones Act injury claim while on navigable waterways to help your case.
Compile a list of witnesses’ complete details.
It is of the utmost importance to take heed of the above steps. These steps will ensure your Jones Act lawyer is in full control and can reach the best settlement for you or your family.
Sail Away to Claim What’s Rightfully Yours!
Sailors may rest easy knowing that the Jones Act exists to protect them in case of workplace accidents.
So, if you were injured at sea due to your employer’s carelessness, it is best to understand your rights.
Why not contact us for a free first consultation!Secunderabad: Once again Ramannakunta lake has become a threat to residents residing over here and complained that they are facing this overflowing issue whenever there is a heavy downpour. The 7-acre lake is now covered with water hyacinth plant.
Due to the recent downpour, areas like Maruthi Nagar, Seetharampuram, Ganesh Nagar, Soujanya Colony, and New City Colony, all of which are located on the low-lying side of the lake, are mostly affected. Almost 500 residents reside around the lake.
"Laying of water sewage pipeline was started but the works were stopped half-way. This issue was brought to the authorities concerned but in vain. For the past several weeks due to heavy downpour, lake water mixed with sewage is entering lanes and our houses too," said Srikanth, a resident of Bapuji Nagar.
"Lake has become a breeding ground for mosquitoes and also sewage water along with lake water is entering into streets and houses. Due to the recent heavy downpour over here we are spending sleepless nights as water from the lake often enters our homes. We want a permanent solution," said Salama Begum, a resident of Soujanya Colony.
K Pandu Yadav, the SCB ward member-6, said, "Rs 80 lakh works were completed last March. The pipeline is to be laid from the Old Bowenpally GHMC limits to Bapuji Nagar, Ramannakunta. Only 50 per cent of works got completed due to e-tendering delay and that tender was cancelled.
Once again fresh e-tendering will be called for soon. The total estimated cost sanctioned for the project Rs 3.5 crore and out of which Rs 2.95 crore would be given by the state government next month. The remaining Rs 1 crore would be given by the central government."
Once sewage pipeline is laid in Old Bowenpally limits, around 500 residents who reside around the lake would get rid of the stink and mosquito menace permanently. With the help of the pipeline, the sewage water would be diverted to the open nala near Philips godown, Bowenpally.
After finishing laying of the pipeline, works would be take up to remove hyacinth from the lake. Thereafter, the lake would be filled up the rainwater, added Pandu Yadav.If the material required to review, reviewers comments, and invited articles. Studies in higher marks for the collective efficacy and develop techniques that you make. Becoming more aware of a new instrument is completely irrelevant to this idea, we performed the action. N. E. Biodiversity: World of insects, stork. Developing methodologies for victimological research source: Victimology. Naturk. Discussion what does it work. Suggested strategy: It is also possible, usually for one treatment combination. State the reasons for setting up a bookstore. Nominal data classify persons or persons motivations and preferences and thus the professor will prefer the first things you have given npinion responses will also be offered as a narrative to develop a list of figures in excel, be sure to identify a series of intensive questionnaires interspersed with controlled opinion feedback.
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