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that petitioner's corporation paid other interest that
petitioners erroneously deducted on their income tax returns for
1990 and 1991. Respondent contends that petitioner's corporation
may have paid some of the interest. We disagree. The Form 1098
bears petitioner's Social Security number, and it was addressed
to petitioner, not his corporation. We conclude that petitioner
paid $8,126 to First Hanover Bank in 1990.5
F. Whether Petitioners Are Liable for the Accuracy-Related
Penalty Under Section 6662(a)
Petitioners contend that they are not liable for the
accuracy-related penalty for negligence for 1990 and 1991 under
section 6662(a) and (c). They contend that they acted reasonably
under the circumstances. We disagree.
Taxpayers are liable for a penalty equal to 20 percent of
the portion of the underpayment to which section 6662 applies.
Sec. 6662(a). For purposes of section 6662(a), negligence
includes any failure to make a reasonable attempt to comply with
the provisions of the Internal Revenue Code. Sec. 6662(c). The
accuracy-related penalty under section 6662(a) does not apply to
any part of an underpayment if the taxpayer shows that there was
reasonable cause for that part of the underpayment and that the
taxpayer acted in good faith. Sec. 6664(c)(1).
5 This is personal interest for reasons discussed above at
par. C-1.
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