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Petitioners' general assertions concerning the fiscal soundness
of the Social Security system are more properly addressed to
Congress than this Court. Fiorito v. Commissioner, supra. We
hold that there is no basis for relieving petitioners of their
liability under existing statutes.
Respondent determined that petitioners are liable for an
accuracy-related penalty pursuant to section 6662. Section
6662(a) imposes a penalty in an amount equal to 20 percent of the
portion of the underpayment of tax attributable to a taxpayer's
negligence or disregard of rules or regulations. Sec. 6662(a)
and (b)(1). Negligence has been defined as the failure to do
what a reasonable and ordinarily prudent person would do under
the circumstances. Neely v. Commissioner, 85 T.C. 934, 947
(1985).
The accuracy-related penalty will apply unless petitioners
can demonstrate that there was reasonable cause for the
underpayment and that they acted in good faith with respect to
the underpayment. Sec. 6664(c). Petitioners have previously
litigated and lost their claims regarding their self-employment
tax obligations for an earlier year.3 On the basis of the entire
3In a prior summary opinion concerning petitioners' tax
liability for that year, we relied on Steiner v. Commissioner, 55
T.C. 1018 (1971), affd. per curiam without published opinion 29
AFTR 2d 72-848, 72-1 USTC par. 9327 (D.C. Cir. 1972), and
rejected petitioners' claim that they need not pay self-
employment tax after they have paid for 40 consecutive quarters.
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