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section 6662(a) accuracy-related penalties for the years in issue
for negligence or disregard of rules or regulations or substantial
understatement of tax.
Section 6651(a)(1) imposes an addition to tax of 5 percent of
the amount of tax due per month for each month that a tax return is
not timely filed. An exception is made for taxpayers demonstrating
reasonable cause. Section 6662(a) imposes a penalty equal to 20
percent of the amount of the underpayment attributable to
negligence or disregard of rules or regulations or substantial
understatement of tax.
On brief, respondent concedes that if we find that there is no
unreported income from bingo operations, then there are no
additions to tax for late filing or penalties for negligence due
from any of the petitioners except the Bullocks. Because we have
concluded that there is no unreported income from the bingo
operations, the Fieldses are not liable for the addition to tax
under section 6651(a)(1), and the Fieldses, Sharpes, and Mr.
Peacock are not liable for the accuracy-related penalties under
section 6662(a) for the years in issue.
The Bullocks have failed to present any credible evidence to
rebut respondent's determination of the accuracy-related penalty or
the addition to tax attributable to the disallowed Schedule C
deductions from the van pool activity. See Tweeddale v.
Commissioner, 92 T.C. 501, 505 (1989) (holding that the taxpayer
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