Nelson J. and Victoria A. Secretario - Page 5

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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                 
               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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