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or disregard of rules or regulations. See sec. 6662(b)(1).
Negligence is the lack of due care or failure to do what a
reasonable and ordinarily prudent person would do under the
circumstances. See Neely v. Commissioner, 85 T.C. 934, 947
(1985). The term "disregard" includes any careless, reckless, or
intentional disregard. Sec. 6662(c). The record in this case
shows that petitioner was negligent and disregarded rules and
regulations. Petitioner has failed to furnish records or
documentation adequate to substantiate his claimed deductions.
Accordingly, we hold that petitioner is liable for the accuracy-
related penalty under section 6662(a).
To reflect the foregoing,
Decision will be
entered under Rule 155.
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Last modified: May 25, 2011