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for the taxable year 1991. Rule 142(a). Based upon the
testimony elicited from petitioner at trial, we find that
respondent has met her burden of demonstrating that the $3,000
business loss deduction claimed for 1991 on the "Horizon America"
Schedule C was duplicative of the business loss deduction claimed
for 1990. Respondent's determination of an increased deficiency
is therefore sustained.
Refund and interest
Petitioners failed to produce any evidence to refute
respondent's determination that petitioner received taxable
interest income in the amount of $369 and a $184 taxable refund
from the State of Arizona during the taxable year 1991.
Accordingly, respondent is sustained on these issues.
Section 6662 penalty
Respondent determined an accuracy-related penalty under
section 6662(a) with respect to petitioners' 1990 Federal income
tax return for negligence or disregard of rules or regulations.
In pertinent part, section 6662 imposes an accuracy-related
penalty equal to 20 percent of the portion of an underpayment of
tax that is attributable to negligence or disregard of rules or
regulations. Sec. 6662(a), (c). Section 6662(c) defines
"negligence" as including any failure to make a reasonable
attempt to comply with the provisions of the Internal Revenue
Code, and defines "disregard" as including any careless,
reckless, or intentional disregard.
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