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here are more similar to those in Aronson than to those in
Larotonda, since petitioner admittedly received amounts from the
qualified retirement plan but failed to roll them over or
reinvest them in an Individual Retirement Account or other
qualified plan.
In view of the foregoing, we hold that petitioner is liable
for the 10-percent additional tax imposed under section 72(t).
Accuracy-Related Penalty
Section 6662(a) imposes a penalty of 20 percent of the
portion of the underpayment which is attributable to any
substantial understatement of income. Sec. 6662(b)(2). There is
a substantial understatement of income tax for any year if the
amount of the understatement exceeds the greater of 10 percent of
the tax required to be shown on the return or $5,000. Sec.
6662(d)(1).
Alternatively, section 6662(a) imposes a penalty of 20
percent on the portion of the underpayment which is attributable
to negligence or disregard of rules or regulations. Sec.
6662(b)(1). Negligence is the lack of due care or 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 term "disregard" includes any careless, reckless, or
intentional disregard. Sec. 6662(c).
However, section 6664(c) provides that no penalty shall be
imposed with respect to any portion of an underpayment if it is
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