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any substantial understatement of income tax. See sec.
6662(a),(b)(1), and (b)(2).
Section 6662(c) provides that the term "negligence" includes
any failure to make a reasonable attempt to comply with the
provisions of this title, and the term "disregard" includes any
careless, reckless, or intentional disregard of rules or
regulations. The Commissioner's determination that a taxpayer
was negligent is presumptively correct, and the burden is on the
taxpayer to show lack of negligence. See Axelrod v.
Commissioner, 56 T.C. 248, 258 (1971). An understatement of tax
is substantial if it exceeds the greater of 10 percent of the tax
required to be shown on the return for the taxable year or
$5,000. See sec. 6662(d)(1)(A)(i) and (ii). The
accuracy-related penalty will apply unless petitioner can
demonstrate that there was reasonable cause for the underpayment
and that he acted in good faith with respect to the underpayment.
See sec. 6664(c)(1).
On the basis of the entire record, we conclude that
petitioner has not established that there was reasonable cause
and that he acted in good faith with respect to the underpayment
of tax. Petitioner did not meet his burden of proving that he
was not negligent. Respondent's deficiency determination exceeds
10 percent of the amount required to be shown on the return and
is more than $5,000. We, therefore, hold that petitioner is
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