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Petitioner did not dispute in her petition or address at
trial respondent's determination that she is liable for the
section 6651(a)(1) addition to tax. We therefore find that she
has failed to prove that her failure to timely file her return
was not due to willful neglect or that such failure was due to
reasonable cause. Accordingly, we hold that petitioner is liable
for the section 6651(a)(1) addition to tax for 1992.
The third issue for decision is whether petitioner is liable
for the section 6662(a) accuracy-related penalty for 1992.
Respondent's determination of negligence is presumed to be
correct, and petitioner bears the burden of proving that the
penalty does not apply. Rule 142(a); Welch v. Helvering, 290
U.S. at 115; Bixby v. Commissioner, 58 T.C. 757, 791-792 (1972).
Section 6662(a) imposes a 20-percent penalty on the portion
of an underpayment attributable to any one of various factors,
one of which is negligence or disregard of rules or regulations.
Sec. 6662(b)(1). Respondent determined that petitioner is liable
for the accuracy-related penalty imposed by section 6662(a) for
her underpayment of tax in 1992, and that such underpayment was
due to negligence or disregard of rules or regulations.
"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
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