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neglect. Sec. 6651(a)(1); Rule 142(a); United States v. Boyle,
469 U.S. 241, 245 (1985). A failure to file timely a Federal
income tax return is due to reasonable cause if the taxpayer
exercised ordinary business care and prudence, and, nevertheless,
was unable to file the return within the prescribed time. Sec.
301.6651-1(c)(1), Proced. & Admin. Regs. Willful neglect means a
conscious, intentional failure or reckless indifference. United
States v. Boyle, supra at 245.
As to the accuracy-related penalty, section 6662(a) imposes
such a penalty equal to 20 percent of the portion of an
underpayment that is attributable to, among other things,
negligence. In order to avoid this penalty, petitioners must
prove that they were not negligent, i.e., that they made a
reasonable attempt to comply with the provisions of the Code, and
that they were not careless, reckless, or in intentional
disregard of rules or regulations. Sec. 6662(c); see also Bixby
v. Commissioner, 58 T.C. 757, 791-792 (1972). Petitioners were
negligent if they displayed a lack of due care or failed to do
what a reasonable and prudent person would do under similar
circumstances. Allen v. Commissioner, 925 F.2d 348, 353 (9th
Cir. 1991), affg. 92 T.C. 1 (1989).
On the basis of our careful review of the record, we hold
that petitioners are liable for both the addition to tax and the
accuracy-related penalty determined by respondent. Petitioners
filed their 1992 tax return on April 19, 1995, and they have not
provided a satisfactory explanation for their failure to file
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