Tracy P. Streber, F.K.A. Tracy C. Parker, et al. - Page 30

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          motion for summary judgment.  Therefore, having redetermined a              
          deficiency of zero, respondent's additions to tax must fail, and            
          we so hold.                                                                 
               B.  The Daughters                                                      
               Respondent determined additions to tax under sections                  
          6653(a)(1) and (2) and 6661 against each of the daughters.                  
               Section 6653(a)(1) provides that, if any part of the                   
          underpayment of tax is due to negligence or intentional disregard           
          of rules or regulations, there shall be added to the tax an                 
          amount equal to 5 percent of the underpayment.  Section                     
          6653(a)(2) imposes a separate addition to tax, equal to                     
          50 percent of the interest payable under section 6601, on the               
          portion of the underpayment that is attributable to the                     
          negligence of the taxpayer.  For purposes of section 6653(a),               
          negligence is defined as the failure to exercise the due care of            
          a reasonable and ordinarily prudent person under like                       
          circumstances.  Neely v. Commissioner, 85 T.C. 934, 947 (1985).             
               Section 6661 provides for an addition to tax equal to                  
          25 percent of the amount of any underpayment attributable to a              
          substantial understatement.  An understatement is "substantial"             
          when the understatement for the taxable year exceeds the greater            
          of (1) 10 percent of the tax required to be shown or (2) $5,000.            
          The understatement is reduced to the extent that the taxpayer               








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