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g. Self-employment Tax Deduction
The amount of the allowable deduction for one-half of the
self-employment tax imposed by section 1401 will be recomputed
under Rule 155.
Issue 3. Additions to Tax and Penalties
Respondent determined additions to tax for late filing for
all years in issue. Petitioner claimed that he was delayed in
filing his returns because he moved his papers to different
locations several times. The record does not support this
assertion. Petitioner is therefore liable for the additions to
tax for late filing as determined by respondent.
Respondent determined an addition to tax for negligence
under section 6653(a)(1) for 1988 and an accuracy-related penalty
for negligence under section 6662(a) for 1989 and 1990.
The addition to tax for negligence under section 6653(a)(1)
is applicable if all or part of an underpayment of tax is due to
negligence or intentional disregard of rules or regulations. The
accuracy-related penalty under section 6662(a) is applicable if
all or part of an underpayment of tax is attributable, among
other things, to negligence or disregard of rules or regulations.
We need not extend this opinion by rehashing the many
instances in each of the years in issue in which petitioner
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