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Except as noted above, petitioner does not attempt to
explain the reason for the failures to file timely. Petitioner
on brief states that she was not asked to give an explanation;
however, petitioner bears the burden of proving reasonable cause
for her failure to file timely, and it is her responsibility to
present any explanation she may have for her conduct. We
accordingly sustain respondent's determinations pursuant to
section 6651(a) for 1990 and 1991.
Section 6662(a) Penalty
Respondent determined that petitioner was liable for the
accuracy-related penalty provided by section 6662(a) for each
year in issue. Section 6662(a) imposes a 20-percent penalty on
the portion of an underpayment of tax that is attributable to,
inter alia, negligence or disregard of rules or regulations. The
term "negligence" includes any failure to make a reasonable
attempt to comply with the provisions of the Code, including
failure to exercise due care or failure to do what a reasonable
person would do in the circumstances. Sec. 6662(c); sec. 1.6662-
3(b)(2), Income Tax Regs. The term "disregard" includes any
careless, reckless, or intentional disregard of the Code or the
temporary or final regulations issued pursuant to the Code. Sec.
6662(c); sec. 1.6662-3(b)(2), Income Tax Regs.
The accuracy-related penalty does not apply to any portion
of an underpayment with respect to which it is shown that there
was a reasonable cause and that the taxpayer acted in good faith.
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