- 56 -
1324, 1343 (1971), affd. without published opinion 496 F.2d 876
(5th Cir. 1974). A taxpayer is required to file timely based on
the best information available and to file thereafter an amended
return if necessary. Estate of Vriniotis v. Commissioner, 79
T.C. 298, 311 (1982). Petitioners did not show what, if any,
efforts they made to obtain information concerning their income
and expenses, nor did they compile the available information to
prepare a reasonably accurate tax return. Under these circum-
stances, we conclude that petitioners have not demonstrated that
their failure to file timely their 1989 and 1990 returns was due
to reasonable cause and not due to willful neglect. We therefore
sustain respondent's determination imposing the addition to tax
on petitioners for each of the years 1989 and 1990 for their
failure to file timely returns for each of those years.
Section 6662
Respondent determined that petitioners are liable for each
of the years 1989 and 1990 for the accuracy-related penalty under
section 6662(a) because their underpayment of tax for each of
those years was due to negligence or disregard of rules or regu-
lations. For purposes of section 6662(a), the term "negligence"
includes any failure to make a reasonable attempt to comply with
the Code, failure to exercise due care, or failure to do what a
reasonable person would do under the circumstances. Sec.
6662(c); Leuhsler v. Commissioner, 963 F.2d 907, 910 (6th Cir.
1992), affg. T.C. Memo. 1991-179; Antonides v. Commissioner, 91
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