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determination that petitioner paid $413,239 in interest charges
for 1990.
Legal Expenses
In her notice of deficiency, respondent disallowed $19,975
in legal expenses claimed as a deduction in 1991. Since peti-
tioner failed to address this issue either at trial or in his
brief, we treat this as a concession by petitioner and find for
respondent.
Penalties
In her notice of deficiency, respondent determined that
petitioners were liable for penalties for fraud pursuant to
section 6663. Prior to trial, respondent conceded that no
amounts were due for fraud. In her answer to the petition,
respondent asserted an accuracy-related penalty against peti-
tioners pursuant to section 6662(a) for their 1990 and 1991
Federal income tax returns. Since the accuracy-related penalty
was first raised in her answer to the petition, respondent has
the burden of proof on this issue.
An accuracy-related penalty equaling 20 percent of the
underpayment may be imposed for any one of five reasons. Sec.
6662(a). One such reason exists where the taxpayer is negligent
in completing his return. Sec. 6662(b)(1). Negligence includes
"any failure to make a reasonable attempt to comply with the
provisions" of the Internal Revenue Code. Sec. 6662(c). This
Court has defined negligence as the "lack of due care or failure
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