Edward S. Cullin - Page 17

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                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 Rule                                    






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