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are, therefore, liable for the addition to tax for substantial
understatement as determined by respondent.
Respondent determined an addition to tax for negligence
under section 6653(a)(1) for 1988 in the amount of $1,425 and an
accuracy-related penalty for negligence under section 6662 for
1989 in the amount of $910. Section 6662(a) imposes a 20-percent
accuracy-related penalty based upon any portion of an
underpayment of tax required to be shown on a return if, as
provided in section 6662(b), the underpayment is attributable,
among other things, to negligence or disregard of rules or
regulations, or any substantial understatement of income tax.
Section 6662(c) includes in the definition of "negligence" any
failure to make a reasonable attempt to comply with the Internal
Revenue title. Petitioners have the burden of proof. Bixby v.
Commissioner, 58 T.C. 757 (1972); see Grzegorzewski v.
Commissioner, T.C. Memo. 1995-49. They have failed to present
any evidence refuting respondent's determination of negligence.
Respondent's determination of negligence is sustained.
To reflect the above,
Decision will be entered for
respondent.
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Last modified: May 25, 2011