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of their personal expenses during the taxable years in issue. We
hold that respondent's determinations are sustained.
2. Accuracy-Related Penalties
The second issue for decision is whether petitioners are
liable for the section 6662(a) accuracy-related penalties for the
taxable years in issue. Respondent's determinations of
negligence are presumed to be correct, and petitioners bear the
burden of proving that the penalties do not apply. Rule 142(a);
Welch v. Helvering, 290 U.S. 111, 115 (1933); Bixby v.
Commissioner, 58 T.C. 757, 791-792 (1972).
Section 6662(a) imposes a 20-percent penalty on the portion
of an underpayment attributable to any one of various factors,
one of which is negligence or disregard of rules or regulations.
Sec. 6662(b)(1). Respondent determined that petitioners are
liable for accuracy-related penalties imposed by section 6662(a)
for the underpayments of tax for 1992, 1993, and 1994 because
such underpayments were due to negligence or disregard of rules
or regulations. "Negligence" includes a failure to make a
reasonable attempt to comply with the provisions of the Internal
Revenue laws or to exercise ordinary and reasonable care in the
preparation of a tax return. Sec. 6662(c); sec. 1.6662-3(b)(1),
Income Tax Regs. "Disregard" includes any careless, reckless, or
intentional disregard of rules or regulations. Sec. 6662(c);
sec. 1.6662-3(b)(2), Income Tax Regs.
Section 6664(c)(1), however, provides that the penalty under
section 6662(a) shall not apply to any portion of an underpayment
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