- 45 -
November 1, 1991. Yet, the parties agree that the application
for additional extension of time was filed in order to extend the
time within which to file his 1990 return to October 15, 1991.
On the record before us, we sustain respondent's determination
under section 6651(a)(1) for 1990 only to the extent that peti-
tioner filed his 1990 return after October 15, 1991.
Section 6662(a)
Respondent determined that petitioner is liable for the
years at issue for the accuracy-related penalty under section
6662(a) because a portion of the underpayment of tax for each of
those years was due to negligence, disregard of rules and regula-
tions, or a substantial understatement of income tax.
Section 6662(a) imposes an addition to tax equal to 20
percent of the underpayment of tax attributable to, inter alia,
(1) negligence or disregard of rules or regulations and (2) any
substantial understatement of income tax. Sec. 6662(b)(1) and
(2). For purposes of section 6662(a), the term "negligence"
includes any failure to make a reasonable attempt to comply with
the Code, and "disregard" includes any careless, reckless, or
intentional disregard. Sec. 6662(c). Negligence has also been
defined as a lack of due care or failure to do what a reasonable
person would do under the circumstances. Leuhsler v. Commis-
sioner, 963 F.2d 907, 910 (6th Cir. 1992), affg. T.C. Memo.
1991-179; Antonides v. Commissioner, 91 T.C. 686, 699 (1988),
affd. 893 F.2d 656 (4th Cir. 1990). With respect to individuals,
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