Keith F. Marason - Page 20

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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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