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because petitioner neglects to address why the mortgage interest
is not nondeductible personal interest, see sec. 163(h), and the
record does not otherwise allow us to conclude that it is not
nondeductible personal interest. Although petitioner is correct
that an individual may deduct investment interest to the extent
that it does not exceed net investment income, sec. 163(d)(1), we
are unpersuaded that the mortgage interest was paid "on
indebtedness properly allocable to property held for investment."
Sec. 163(d)(3). We hold for respondent on this issue.
Respondent also determined that petitioner's underpayment of
income tax was due to negligence, and, accordingly, that
petitioner was liable for the penalty under section 6662(a).
Section 6662(a) imposes an accuracy-related penalty equal to
20 percent of the portion of an underpayment that is attributable
to negligence. In order to avoid this penalty, petitioner must
prove that she was not negligent, i.e., she made a reasonable
attempt to comply with the provisions of the Internal Revenue
Code, and that she was not careless, reckless, or in intentional
disregard of rules or regulations. Sec. 6662(c); Drum v.
Commissioner, T.C. Memo. 1994-433, affd. without published
opinion 61 F.3d 910 (9th Cir. 1995); see also Allen v.
Commissioner, 925 F.2d 348, 353 (9th Cir. 1991) (negligence also
defined as a lack of due care or a failure to do what a
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