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"Negligence" includes a failure to make a reasonable attempt to
comply with the provisions of the Internal Revenue laws or to
exercise ordinary and reasonable care in the preparation of a tax
return. Sec. 6662(c); sec. 1.6662-3(b)(1), Income Tax Regs.
"Disregard" includes any careless, reckless, or intentional
disregard of rules or regulations. Sec. 6662(c); sec.
1.6662-3(b)(2), Income Tax Regs.
We find that petitioners have failed to prove that they were
not negligent in their underpayment of tax. Although petitioners
blame respondent for their lack of knowledge, the rules and
regulations concerning their proper tax liability are readily
available to the public through various sources. Therefore, we
hold that petitioners are liable for the section 6662(a)
accuracy-related penalty for 1991.
We will next determine whether this Court should impose
sanctions upon petitioners pursuant to section 6673.
Whenever it appears to this Court that the taxpayer's
position in a proceeding before it is frivolous or groundless the
Court, in its discretion, may require the taxpayer to pay to the
United States a penalty not in excess of $25,000. Sec.
6673(a)(1)(B). A proceeding in the Tax Court is frivolous "if it
is contrary to established law and unsupported by a reasoned,
colorable argument for change in the law." Coleman v.
Commissioner, 791 F.2d 68, 71 (7th Cir. 1986). Sanctions are
properly imposed when the taxpayer knew or should have known that
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