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through 1990 were not timely filed. Furthermore, there is
nothing in this record that would even remotely indicate that
these failures were due to reasonable cause and not due to
willful neglect. Therefore, we sustain respondent's
determinations with respect to the additions to tax under section
6651(a) for all the years at issue.
Sections 6653(a) and 6662(a) impose additions to tax and
penalties for negligence or disregard of rules or regulations.
If any part of the underpayment is due to negligence, under
section 6653(a)(1) the addition to tax is equal to 5 percent of
the amount of the underpayment. Under section 6662(a) the
accuracy-related penalty is equal to 20 percent of the portion of
the underpayment due to negligence. It is clear that petitioner
is liable for these additions to tax and accuracy-related
penalties. Under section 6001 a taxpayer is required to keep
records. As far as we can determine, petitioner kept no records
from which his (taxable) income could be determined. While
petitioner used accounting firms to prepare his returns, as far
as Mr. Moore was concerned, petitioner supplied the information
in summary fashion. None of the other return preparers
testified. With respect to petitioner's gross income, the
information was greatly understated. Furthermore, with regard to
the accuracy-related penalties, the entire underpayment for each
of the taxable years 1989 and 1990 was attributable to
negligence. We sustain respondent's determinations with respect
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