22
Petitioner filed his 1991 return on March 5, 1993, and his
1992 return on October 23, 1993. Petitioner offered no evidence
relating to this addition to tax. We conclude that petitioner is
liable for the addition to tax under section 6651(a)(1) for 1991
and 1992.
2. Whether Petitioner Is Liable for the Accuracy-Related
Penalty Under Section 6662
Respondent determined that petitioner is liable for the
accuracy-related penalty for negligence for 1991 and for
substantial understatement for 1992. Sec. 6662(a), (c), (d).
Taxpayers are liable for a penalty equal to 20 percent of
the part of the underpayment to which section 6662 applies. Sec.
6662(a). Section 6662 applies to an underpayment attributable to
negligence or to a substantial understatement of income tax.
Sec. 6662(b)(1) and (2). Negligence includes a failure to try
reasonably to comply with internal revenue laws or to exercise
ordinary and reasonable care in preparing a tax return. Sec.
6662(c). A substantial understatement of income tax occurs when
the amount of the understatement for a taxable year exceeds the
greater of 10 percent of the tax required to be shown or $5,000.
Sec. 6662(d)(1)(A). The accuracy-related penalty does not apply
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