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             than to purchase tobacco or that they are deductible in                  
             connection with an activity other than Beaufort Leaf's                   
             business of purchasing and selling tobacco.  Cf. Brizell                 
             v. Commissioner, 93 T.C. 151 (1989).                                     
             Penalties and Additions to Tax                                           
                  The third issue for decision is whether petitioners                 
             are liable for the penalties and addition to tax determined              
             in the notices of deficiency.  Respondent determined an                  
             accuracy-related penalty under section 6662(a) with respect              
             to each petitioner's returns for 1990 and 1991.  Section                 
             6662 imposes a penalty of 20 percent of the portion of an                
             underpayment of tax related to, inter alia, "Negligence or               
             disregard of rules or regulations" or "Any substantial                   
             understatement of income tax".  For this purpose, the term               
             "negligence" includes any failure to make a reasonable                   
             attempt to comply with the provisions of the income tax,                 
             and the term "disregard" includes any careless, reckless,                
             or intentional disregard.  Sec. 6662(c).  In substance,                  
             an understatement of income tax is the excess of the                     
             amount of tax required to be shown on the taxpayer's return              
             over the amount that is shown on the return.  See sec.                   
             6662(d)(2)(A).  A substantial understatement is defined                  
             by section 6662(d)(1)(A) as an understatement exceeding                  
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