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Income Tax Regs. The term "disregard" includes any careless,
reckless, or intentional disregard of rules or regulations. Sec.
6662(c); sec. 1.6662-3(b)(2), Income Tax Regs.
Section 6664(c)(1), however, provides that the penalty under
section 6662(a) shall not apply to any portion of an underpayment
if it is shown that there was reasonable cause for the taxpayer's
position with respect to that portion and that the taxpayer acted
in good faith with respect to that portion. The determination of
whether a taxpayer acted with reasonable cause and in good faith
within the meaning of section 6664(c)(1) is made on a case-by-
case basis, taking into account all the pertinent facts and
circumstances. Sec. 1.6664-4(b)(1), Income Tax Regs.
Respondent's determination of negligence is presumed to be
correct, and petitioners bear the burden of proving that the
accuracy-related penalty does not apply. Rule 142(a); Welch v.
Helvering, 290 U.S. at 115.
Petitioners have not presented evidence to establish that
there was reasonable cause for their position with respect to the
underpayments of tax, nor that they acted in good faith with
respect to such underpayments. At first glance, petitioners
appear to have put their records together very well. However,
careful scrutiny of the documentary evidence presented and
petitioner's trial testimony proves this assumption wrong. We
found numerous instances where petitioners took multiple
deductions for the same item, claimed deductions for items that
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