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Commissioner, T.C. Memo. 1995-577, affd. without published
opinion 106 F.3d 386 (3d Cir. 1996). Since there is no evidence
in this record from which the Court can make findings as to
petitioners' claimed deductions, respondent's determination is
sustained.
Respondent determined petitioners were liable for the
accuracy-related penalty under section 6662(a) for 1995. The
accuracy-related penalty is equal to 20 percent of any portion of
an underpayment of tax required to be shown on the return that is
attributable to the taxpayer's negligence or disregard of the
rules or regulations. See sec. 6662(a) and (b)(1). "Negligence"
consists of any failure to make a reasonable attempt to comply
with the provisions of the Internal Revenue Code. Sec. 6662(c).
"Disregard" consists of any careless, reckless, or intentional
disregard. Id.
It is the taxpayer's responsibility to establish he is not
liable for the accuracy-related penalty imposed by section
6662(a). See Rule 142(a); Tweeddale v. Commissioner, 92 T.C.
501, 505 (1989). Petitioner failed to explain adequately the
nature of his business and how claimed expenses related to that
business. He further failed to present any evidence as to
itemized deductions. On the basis of the entire record, we
conclude that petitioners have not established the underpayment
of tax was due to reasonable cause and that they acted in good
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