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the same circumstances. Neely v. Commissioner, 85 T.C. 934, 947
(1985). The penalty does not apply to any portion of an
underpayment for which there was reasonable cause and with
respect to which the taxpayer acted in good faith. Sec. 6664(c).
Generally, respondent's determination imposing the accuracy-
related penalty is presumed correct, and taxpayers bear the
burden of proving that they are not liable for the accuracy-
related penalty imposed by section 6662(a). Rule 142(a);
Tweeddale v. Commissioner, 92 T.C. 501, 505 (1989). Respondent,
however, bears the burden of proving petitioner's liability for
an accuracy-related penalty with regard to petitioner's claim
that his daughter was his dependent in 1990. See supra note 3.
With respect to 1990, we find that petitioner did not have a
reasonable basis either for claiming his daughter as a dependent,
or for characterizing his worthless note as a business bad debt.
With respect to 1991, we conclude that petitioner did not have a
reasonable basis for claiming a deduction for theft losses
relating to amounts withheld from his wages by his former wife.
Furthermore, petitioner offered no evidence to suggest that he
had a reasonable basis for any of the conceded items which
resulted in an underpayment. Accordingly, we sustain
respondent's determination to this extent. However, we find that
petitioner made reasonable attempts to comply with statutory
requirements when claiming his mother as a dependent in 1991.
Moreover, we find that petitioner had a reasonable belief that
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