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time. Crocker v. Commissioner, 92 T.C. 899, 913 (1989); sec.
301.6651-1(c)(1), Proced. & Admin. Regs.
Petitioner offers no argument that he is not liable for the
addition to tax for failure to timely file his 1989 return. We
treat this as a concession by petitioner. Rothstein v.
Commissioner, 90 T.C. 488, 497 (1988); Reaves v. Commissioner, 31
T.C. 690, 722 (1958), affd. 295 F.2d 336 (5th Cir. 1961). We
conclude that petitioner is liable for the addition to tax under
section 6651(a)(1) for failure to timely file his income tax
return for 1989.
C. Whether Petitioner Is Liable for the Accuracy-Related
Penalty Under Section 6662(a)
Respondent determined that petitioner is liable for the
accuracy-related penalty for negligence for 1989 under section
6662(a).
Taxpayers are liable for a penalty equal to 20 percent of
the part of the underpayment to which section 6662 applies. Sec.
6662(a). For purposes of section 6662(a), negligence includes
any failure to make a reasonable attempt to comply with the
provisions of the Internal Revenue Code. Sec. 6662(c). The
accuracy-related penalty under section 6662(a) does not apply to
any part of an underpayment if the taxpayer shows that there was
reasonable cause for that part and that the taxpayer acted in
good faith. Sec. 6664(c)(1).
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