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underpayment if any part of the underpayment is attributable to
negligence. For 1986 and 1987, section 6653(a)(1)(A) and (B)
replaced former section 6653(a) but is similar in form. Section
6653(a)(1)(A) imposes an addition to tax equal to 5 percent of
the underpayment if any part of the underpayment is attributable
to negligence. Section 6653(a)(1)(B) imposes an addition to tax
equal to 50 percent of the interest payable on the portion of the
underpayment attributable to negligence. For 1988, Congress
replaced former section 6653(a)(1)(A) and (B) with section
6653(a). Section 6653(a) was similar to former section
6653(a)(1)(A). Section 6653(a) imposes an addition to tax equal
to 5 percent of the portion of the underpayment attributable to
negligence. Section 6653(a)(1)(B), however, has no counterpart
for 1988. For 1989, 1990, 1991, 1992, and 1993, section 6662
replaced former section 6653(a). Section 6662(a) and (b)(1)
imposes a penalty equal to 20 percent of the portion of the
underpayment that is attributable to negligence or disregard of
rules or regulations. For purposes of all of these provisions,
negligence is defined as a lack of due care or failure to do what
a reasonable or ordinarily prudent person would do under similar
circumstances. See Neely v. Commissioner, 85 T.C. 934, 947
(1985).
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