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Respondent determined that petitioners are liable for the
accuracy-related penalty imposed by section 6662(a) for their
underpayments of taxes for 1990, 1991, and 1992 that are
attributable to their disallowed charitable contribution
deductions, and that such underpayments were due to negligence or
disregard of rules or regulations.
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.
See sec. 6662(b)(1). "Negligence" includes any 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. See sec. 6662(c); sec.
1.6662-3(b)(1), Income Tax Regs. It also includes any failure to
keep adequate books and records or to substantiate items
properly. See sec. 1.6662-3(b)(1), Income Tax Regs. "Disregard"
includes any careless, reckless, or intentional disregard of
rules or regulations. See sec. 6662(c); sec. 1.6662-3(b)(2),
Income Tax Regs.
Section 6664(c)(1), however, provides that the section
6662(a) penalty shall not apply to any portion of an
underpayment, if it is shown that there was reasonable cause for
the taxpayer's position with respect to that portion of the
underpayment and that the taxpayer acted in good faith with
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