- 24 -
would do under the circumstances. Neely v. Commissioner, 85 T.C.
934, 947 (1985).
However, under section 6664(c), no penalty shall be imposed
under section 6662(a) with respect to any portion of an
underpayment if it is shown that there was a reasonable cause for
such portion and that the taxpayer acted in good faith with
respect to such portion. The Commissioner's determination is
presumptively correct and will be upheld unless the taxpayer is
able to rebut the presumption. Luman v. Commissioner, 79 T.C.
846, 860-861 (1982); Bixby v. Commissioner, 58 T.C. 757 (1972);
Reily v. Commissioner, 53 T.C. 8 (1969).
In the notice of deficiency, respondent applied the section
6662(a) penalty to "all of the underpayment of tax" for each of
the years at issue, due to petitioner's "negligence or
intentional disregard of rules or regulations".
With regard to those adjustments conceded by petitioner and
those sustained by this Court, petitioner presented no evidence
to show that she used due care in failing to report interest
income, claiming dependency exemptions, claiming head-of-
household filing status, and claiming the casualty loss
deduction, nor did she present evidence to show that she had
reasonable cause to omit such items of income and claim such
exemptions, deductions, and filing status.
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