- 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 Rule
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