Shizuo George Kurata - Page 17

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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                                

                                                            Decision will be entered                  
                                                      under Rule 155.                                 

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