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tax return is adequate disclosure under section 6661. Sec.
1.6661-4(c), Income Tax Regs. Section 4(a)(5) of Rev. Proc. 89-
11, 1989-1 C.B. 797, 798, provides that to adequately disclose a
casualty loss for purposes of section 6661, the taxpayer must
complete Form 4684 and attach it to the return.
Petitioner attached Forms 4684 to the amended returns she
filed for 1985, 1986, and 1987. In them, she described her real
and personal property loss from the earthquake. She included a
detailed inventory of her personal property that was damaged
or destroyed by the earthquake. We conclude that petitioner
adequately disclosed her casualty loss on her 1985, 1986,
and 1987 returns. Rev. Proc. 89-11, sec. 4(a)(5). Thus, we
hold that petitioner is not liable for the addition to tax under
section 6661 for 1985, 1986, and 1987.
3. Accuracy-Related Penalty
Taxpayers are liable for a penalty equal to 20 percent
of the part of the underpayment attributable to negligence or
disregard of rules or regulations. Sec. 6662(a) and (b)(1).
Negligence includes a failure to make a reasonable attempt to
comply with the provisions of the internal revenue laws or to
exercise ordinary and reasonable care in the preparation of a
tax return. Sec. 6662(c).
Petitioner bears the burden of proving that she is
not liable for the accuracy-related penalty. Rule 142(a).
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