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1993. Section 6662 imposes an accuracy-related penalty equal to
20 percent of any portion of an underpayment of tax that is
attributable to negligence or disregard of rules or regulations.
See sec. 6662(a) and (b). The term "negligence" means "any
failure to make a reasonable attempt to comply with the
provisions of [the Code]". Sec. 6662(c). This includes any
failure to exercise due care or to do what a reasonable and
ordinarily prudent person would do under the circumstances.
See Rybak v. Commissioner, 91 T.C. 524, 565 (1988); Neely v.
Commissioner, 85 T.C. 934, 947 (1985). The term "disregard"
includes any careless, reckless, or intentional disregard.
Sec. 6662(c).
Petitioner must prove respondent's determination of
negligence wrong. Rule 142(a); Bixby v. Commissioner, 58 T.C.
757, 791 (1972). Petitioner's complete argument against this
penalty is: "As the foregoing discussion and Proposed Findings
demonstrate, * * * [petitioner] had a solid basis for * * * [his]
tax position. No grounds exist for imposing penalties under IRC
� 6662(a)." We disagree; we are unable to find that petitioner
had a solid basis for his positions herein. Petitioner is a
sophisticated and longtime businessman who holds a business
degree from Duke University. Yet he deliberately painted his
settlement agreement with Balfour to appear that he received the
settlement payment for a personal injury although he knew that
the payment was intended to compensate him for taxable
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