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found it : Accuracy-related penalty. You have to pay an accuracy-related penalty if you underpay your tax because: You show negligence or disregard of the rules or regulations, or You substantially understate your income tax. The penalty is equal to 20% of the underpayment. The penalty not be figured on any part of an underpayment on which the fraud penalty (discussed later) is charged. Negligence or disregard. The term “negligence” includes a failure to make a reasonable attempt to comply with the tax law or to exercise ordinary and reasonable care in preparing a return. Negligence also includes failure to keep adequate books and records. You not have to pay a negligence penalty if you have a reasonable basis for a position you took. The term “disregard” includes any careless, reckless, or intentional disregard. Adequate disclosure. You can avoid the penalty for disregard of rules or regulations if you adequately disclose on your return a position that has at least a reasonable basis. Disclosure statement, later. This exception not apply to an item that is attributable to a tax shelter. In addition, it not apply if you fail to keep adequate books and records, or substantiate items properly. Substantial understatement of income tax. You understate your tax if the tax shown on your return is less than the correct tax. The understatement is substantial if it is more than the larger of 10% of the correct tax or $5. However, the amount of the understatement be reduced to the extent the understatement is due to: Substantial authority, or Adequate disclosure and a reasonable basis. If an item on your return is attributable to a tax shelter, there is no reduction for an adequate disclosure. However, there is a reduction for a position with substantial authority, but only if you reasonably believed that your tax treatment was more likely than not the proper treatment. lonely wife in Mazra`eh Ibrahim
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