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rules or regulations. The term "negligence" includes any failure
to make a reasonable attempt to comply with the statute, and the
term "disregard" includes any careless, reckless, or intentional
disregard. Sec. 6662(c). The penalty does not apply to any
portion of an underpayment for which there was reasonable cause
and with respect to which the taxpayer acted in good faith. Sec.
6664(c). Respondent's imposition of the section 6662(a) penalty
is presumptively correct, and petitioners bear the burden of
proving that they are not liable for the accuracy-related penalty
under section 6662(a). Rule 142(a); cf. Welch v. Helvering, 290
U.S. 111, 115 (1933); Bixby v. Commissioner, 58 T.C. 757, 791-792
(1972).
Petitioners have conceded all of the adjustments made in the
notice of deficiency, which adjustments gave rise to respondent's
imposition of the accuracy-related penalty. They have offered no
evidence or explanation of the circumstances surrounding the
filing of their 1990 Federal income tax return, other than it was
prepared by Roger G. Cotner. Respondent argues that as an
attorney, Roger G. Cotner should have known that certain of the
deductions claimed on the 1990 Form 1040 were "blatantly wrong",
evidenced by their concessions in this case. We note that as a
practicing attorney, Roger G. Cotner is held to a higher standard
of care than other taxpayers. Tippin v. Commissioner, 104 T.C.
518 (1995). Petitioners' failure to explain the circumstances
surrounding the preparation and filing of their 1990 Federal
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