- 17 - Commissioner, 61 T.C. 278, 288 n.6 (1973); Bernstein v. Commissioner, 22 T.C. 1146, 1152 (1954), affd. 230 F.2d 603 (2d Cir. 1956). Moreover, the record of this case suggests that petitioner incurred the subject losses in connection with his manuscript, presumably a "literary" work. See Quinn v. Commissioner, T.C. Memo. 1974-64; cf. Crouch v. Commissioner, T.C. Memo. 1990-309. The phrase "research or experimental expenditures", however, does not include expenditures for "Research in connection with literary * * * projects." Sec. 1.174-2(a)(3), Income Tax Regs. The next issue for decision involves respondent's determination that petitioner is liable for the accuracy- related penalty imposed by section 6662(a). Respondent determined that the entire underpayment for 1989, $27,650.70, and a portion of the underpayment for 1990, $17,224, is attributable to negligence or disregard of rules or regulations. See sec. 6662(a) and (b)(1). The term "negligence" includes any failure to make a reasonable attempt to comply with the statute, and the term "disregard" includes any careless, reckless, or intentional disregard. Sec. 6662(c). Respondent's determinations are presumed correct, and petitioner bears the burden of proving that he is not liable for the accuracy-related penalty. Rule 142(a). All RulePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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