Prindle International Marketing, UBO, Keyus Group, Trustee - Page 19

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          to cancel their business relationship.  Thus, Gump differs from             
          this case.                                                                  
               We conclude that Mr. and Mrs. Fox are liable for self-                 
          employment tax of $10,658 for 1992 and $11,057 for 1993.                    
          F.   Whether Mr. and Mrs. Fox Are Liable for the Addition to Tax            
               for Failure To File for 1993 and the Accuracy-Related                  
               Penalty for 1989, 1992, and 1993                                       
               Respondent determined and contends that Mr. and Mrs. Fox are           
          liable for the addition to tax for failure to file an income tax            
          return for 1993 under section 6651(a) and the accuracy-related              
          penalty for 1989, 1992, and 1993 under section 6662(a) for                  
          negligence.                                                                 
               1.   Section 6651(a)(1)                                                
               A taxpayer is liable for an addition to tax of up to 25                
          percent for failure to file timely Federal income tax returns               
          unless the taxpayer shows that such failure was due to reasonable           
          cause and not willful neglect.  Sec. 6651(a)(1); United States v.           
          Boyle, 469 U.S. 241, 245 (1985); Davis v. Commissioner, 81 T.C.             
          806, 820 (1983), affd. without published opinion 767 F.2d 931               
          (9th Cir. 1985).                                                            
               2.   Section 6662(a)                                                   
               Taxpayers are liable for a penalty under section 6662 equal            
          to 20 percent of the part of the underpayment which is                      
          attributable to negligence.  Sec. 6662(a).  For purposes of                 
          section 6662(a), negligence is a failure to reasonably attempt to           
          comply with the Internal Revenue Code.  Sec. 6662(c).  The                  




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