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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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