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Addition to Tax
Section 6651(a)(1) imposes an addition to tax for failure to
timely file a return, unless the taxpayer establishes that the
failure to file is due to reasonable cause and not due to willful
neglect. The addition to tax equals 5 percent of the tax
required to be shown on the return for the first month, with an
additional 5 percent for each additional month or fraction of a
month during which the failure to file continues, not to exceed a
maximum of 25 percent. Sec. 6651(a)(1).
In her brief, petitioner conceded that section 6651(a)
applies with respect to the year 1989 and for reasons unexplained
only disputes the amount as computed by respondent. Petitioner
presented no evidence or argument demonstrating the nature of the
alleged computational error. Accordingly, we sustain respondent
with respect to this issue.
Accuracy-Related Penalty
In her answer, respondent asserted that the section 6662(a)
penalty should be imposed. Respondent argues for the imposition
of the penalty due to petitioner's negligence or disregard of
rules or regulations within the meaning of section 6662(b)(1) and
(c), or because petitioner substantially understated her income
tax, within the meaning of section 6662(b)(2) and (d).
Negligence includes any failure to make a reasonable attempt to
comply with the provisions of the internal revenue laws or to
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