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possession of Mr. Terrell's business records indicates a lack of
causal link between their failure to file and the riots and fires
occurring near their home.
Under these circumstances, we conclude that petitioners'
failure to file their 1991, 1992, and 1993 income tax returns was
not due to reasonable cause. Therefore, respondent properly
imposed the addition to tax.
II. Accuracy-Related Penalty Under Section 6662(a)
Respondent determined that petitioners were liable for the
accuracy-related penalty under section 6662(a) for their 1991,
1992, and 1993 taxable years, respectively. Section 6662(a)
imposes an accuracy-related penalty of 20 percent on any portion
of an underpayment of tax that is attributable to items set forth
in section 6662(b). Section 6662(b)(1) applies section 6662(a)
to any portion of an underpayment attributable to negligence or
disregard of rules or regulations.
Petitioners must prove that they were not negligent; i.e.,
that they made a reasonable attempt to comply with the provisions
of the Internal Revenue Code, and that they were not careless,
reckless, or intentional disregard of rules or regulations. See
sec. 6662(c); Rule 142(a); LaVerne v. Commissioner, 94 T.C. 637,
652 (1990), affd. without published opinion 956 F.2d 274 (9th
Cir. 1992); sec. 1.6662-3(b), Income Tax Regs. "Negligence" has
also been defined as a "lack of due care or failure to do what a
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