- 27 -27
petitioners conceded, see supra note 1) and thus failed to meet her
burden of proof with respect to those items. Rule 142(a).
Thus, we hold that Mrs. Taylor is not entitled to innocent
spouse relief and is liable for the deficiencies for the years in
issue.
Issue 4. Negligence, Substantial Understatement, and Failure To
File
The final issue for decision is whether petitioners are liable
for additions to tax for negligence or disregard of rules or
regulations pursuant to section 6653(a)(1), substantial
understatement of tax pursuant to section 6661(a), and failure to
file their Federal tax return pursuant to section 6651(a)(1) for
1988; and whether petitioners are liable for accuracy-related
penalties pursuant to section 6662 for negligence or disregard of
rules or regulations, or substantial understatement of tax for 1989
and 1990. Respondent made these determinations as an alternative
to the fraud addition to tax and penalties.
For 1988, section 6653(a)(1) imposes an addition to tax equal
to 5 percent of the underpayment if any part of the underpayment is
attributable to negligence or disregard of rules or regulations.
"Negligence" means any failure to make a reasonable attempt to
comply with the Internal Revenue Code, and "disregard" includes any
careless, reckless, or intentional disregard. Sec. 6653(a)(3).
For 1988, section 6661(a) imposes an addition to tax equal to 25
percent of the amount of any underpayment attributable to a
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