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of checks written in 1990. It is unclear which of these, if any,
purportedly substantiate the $126 disallowed by respondent.
Petitioners have not satisfied their burden of proof. Respondent
is sustained on this issue.
7. Negligence
For taxable years 1989, 1990, and 1991, respondent
determined that petitioners are liable for the accuracy-related
penalty under section 6662(a) for negligence in the respective
amounts of $845, $901, and $1,125. Section 6662(a) and (b)(1)
imposes an accuracy-related penalty on any portion of an
underpayment which is attributable to negligence or disregard of
rules or regulations. Negligence is the lack of due care or
failure to do what a reasonable and ordinarily prudent person
would do under the circumstances. Neely v. Commissioner, 85 T.C.
934, 947 (1985). The term "disregard" includes any careless,
reckless, or intentional disregard. Sec. 6662(c). Petitioners
have the burden of proof to show that the penalty should not be
sustained by the Court. Rule 142(a); Tweeddale v. Commissioner,
92 T.C. 501, 505 (1989).
Petitioners submitted one piece of evidence with respect to
the negligence penalty, a one-paragraph statement clipped from a
text, magazine, or pamphlet offering tax tips. This particular
clipping states that business expenses of writers are deductible
in the year incurred and need not be expensed over time.
Petitioners' reliance on this comment, regardless of its
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