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attempt to comply with the provisions of the internal revenue
laws, and the term “disregard” includes any careless, reckless,
or intentional disregard. Sec. 6662(c).
In the notice of deficiency, respondent determined that the
entire underpayment of tax for the 1989 taxable year was due to
petitioner's negligence or intentional disregard of rules and
regulations. Petitioner bears the burden of proving that
respondent's determination is erroneous. See Rule 142(a). On
the record before us, we find that respondent's determination of
a penalty under section 6662(a) is correct, except to the extent
that it relates to the section II.A. difference, supra.
IV. Conclusion
Respondent's determinations of a deficiency in, an addition
to, and a penalty on petitioner's Federal income tax for the 1989
taxable year are sustained to the extent set forth in this
report.
Decision will be entered
under Rule 155.
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