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of the items set forth in section 6662(b). Respondent asserts
that the entire underpayment of petitioner’s tax was due to
negligence or intentional disregard of rules or regulations.
Petitioner bears the burden of proving that respondent's
determinations are erroneous. Rule 142(a); Bixby v.
Commissioner, 58 T.C. 757, 791 (1972).
“Negligence” includes a failure to make a reasonable attempt
to comply with the provisions of the internal revenue laws. Sec.
6662(c); sec. 1.6662-3(b)(1), Income Tax Regs. “Disregard”
includes any careless, reckless, or intentional disregard of
rules or regulations. Sec. 6662(c); sec. 1.6662-3(b)(2), Income
Tax Regs. Large understatements of income have been held to be
indicative of negligence or intentional disregard of the rules or
regulations. See Anders v. Commissioner, 68 T.C. 474, 493
(1977).
The section 6662 accuracy-related penalty does not apply
with respect to any portion of an underpayment if it is shown
that there was reasonable cause for such portion and that
petitioner acted in good faith with respect to such portion.
Sec. 6664(c)(1). The determination of whether petitioner acted
with reasonable cause and in good faith depends upon the
pertinent facts and circumstances. Sec. 1.6664-4(b)(1), Income
Tax Regs.
Petitioner claims that he relied on the Internal Revenue
Service (IRS) information hotline and the Form 1040 instructions
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