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338 F.2d 602, 605 (9th Cir. 1964), affg. 41 T.C. 593 (1964);
Tokarski v. Commissioner, 87 T.C. 74, 77 (1986). Since we are
unwilling to accept petitioner’s testimony without some
corroboration on this issue, we sustain respondent’s adjustment
disallowing petitioner’s wage deduction.
Accuracy-Related Penalty
Respondent has proposed an accuracy-related penalty against
petitioner for 1994 under section 6662(a). Section 6662(a)
authorizes respondent to impose a penalty in an amount equal to
20 percent of the portion of the underpayment attributable to
negligence or disregard of rules or regulations. Negligence is
defined as “any failure to make a reasonable attempt to comply
with the provisions of * * * [the Internal Revenue Code]”. Sec.
6662(c); see also Neely v. Commissioner, 85 T.C. 934, 947 (1985)
(negligence is lack of due care or failure to do what a
reasonable and prudent person would do under the circumstances).
Negligence also includes any failure by the taxpayer to keep
adequate books and records or to substantiate items properly.
See sec. 1.6662-3(b)(1), Income Tax Regs. The term “disregard”
includes any careless, reckless, or intentional disregard. Sec.
6662(c). Disregard of rules or regulations is careless if the
taxpayer does not exercise reasonable diligence to determine the
correctness of a return position that is contrary to the rule or
regulation. See sec. 1.6662-3(b)(2), Income Tax Regs. A
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