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question, petitioner failed to show that any such illnesses or
injuries incapacitated her to the point that she could not, with
reasonable effort, file on time her Federal income tax returns
for the years at issue. The Court finds, on this record, that
petitioner's Federal income tax returns for 1990, 1991, and 1992
were not filed timely and that the late filings were not due to
reasonable cause. Respondent, therefore, is sustained on this
issue.
The final issue is whether petitioner is liable for the
accuracy-related penalty under section 6662(a) for negligence or
disregard of rules or regulations, for 1989, 1990, 1991, and
1992. Section 6662(a) provides that, if it is applicable to any
portion of an underpayment in taxes, there shall be added to the
tax an amount equal to 20 percent of the portion of the
underpayment to which section 6662 applies. Section 6662(b)(1)
provides that section 6662 shall apply to any underpayment
attributable to negligence or disregard of rules or regulations.
Section 6662(c) provides that the term "negligence" includes
any failure to make a reasonable attempt to comply with the
provisions of the Internal Revenue laws, and the term "disregard"
includes any careless, reckless, or intentional disregard of
rules or regulations. Negligence is the lack of due care or
failure to do what a reasonable and ordinarily prudent person
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