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United States v. Boyle, 469 U.S. 241, 245 (1985); Catalano v.
Commissioner, 81 T.C. 8 (1983). A failure to file timely is due
to reasonable cause if the taxpayer exercised ordinary business
care and prudence, and, nevertheless, was unable to file the
return within the prescribed time. Sec. 301.6651-1(c)(1),
Proced. & Admin. Regs. Willful neglect means a conscious,
intentional failure or reckless indifference. United States v.
Boyle, supra at 245.
Petitioner filed its return for its 1989 taxable year almost
8 months past the due dates prescribed in sections 6072(b) and
6081(b). Petitioner has provided no evidence to overcome
respondent's determination that it is liable for the addition to
tax for failure to file timely. We sustain respondent on this
issue.
4. Section 6662
Respondent also determined accuracy-related penalties under
section 6662 for petitioner’s 1989, 1990, and 1991 taxable years.
Section 6662(a) imposes an accuracy-related penalty equal to
20 percent of the portion of the underpayment that is
attributable to negligence. Sec. 6662(b)(1). For purposes of
section 6662(a), “negligence” includes a “failure to make a
reasonable attempt to comply with the Internal Revenue Code”, and
"disregard" includes careless, reckless, or intentional
disregard. Sec. 6662(c); sec. 1.6662-3(b)(1), Income Tax Regs.
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