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indicates that they tried to reconstruct the information
contained in these worksheets. Accordingly, we find that
petitioners are not entitled to the bad debt deductions claimed
on their 1994 and 1995 Federal income tax returns.
Petitioners also have not furnished any documentation that
substantiates their claim that they included the interest income
from First Union National Bank of Florida on their 1994 Federal
income tax return. Accordingly, we find for respondent on this
issue.
Section 6662(a) imposes a penalty of 20 percent of the
portion of the underpayment which is attributable to negligence
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). In general,
taxpayers are required to "keep such permanent books
of account or records, including inventories, as are
sufficient to establish the amount of gross income,
deductions, credits, or other matters required to be
shown by such person in any return of such tax or
information." Sec. 1.6001-1(a), Income Tax Regs.
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