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not remember what these items were.
On the basis of these facts, we find that petitioner has not
met his burden of proving that he expended the amount he claimed
as a job-search expense. Respondent is sustained on this issue.
Issue 5. Accuracy-Related Penalty
Finally, we must decide whether petitioner is liable for the
accuracy-related penalty under section 6662(a). Section 6662
imposes a penalty equal to 20 percent of the portion of the
underpayment that is attributable to negligence or disregard of
rules or regulations. See sec. 6662(a) and (b)(1).
For purposes of this section, the term "negligence" includes
any failure to make a reasonable attempt to comply with the
provisions of the internal revenue laws, a failure to exercise
ordinary and reasonable care in the preparation of a tax return,
and a failure to keep adequate books and records or to
substantiate items properly. See sec. 1.6662-3(b)(1), Income Tax
Regs. Negligence is defined as a lack of due care or failure to
do what a reasonable and ordinarily prudent person would do under
the circumstances. See Zmuda v. Commissioner, 731 F.2d 1417,
1422 (9th Cir. 1984), affg. 79 T.C. 714 (1982); Neely v.
Commissioner, 85 T.C. 934, 947 (1985). The term "disregard"
includes any careless, reckless, or intentional disregard of the
rules or regulations. See sec. 6662(c).
Just as with respondent's deficiency determination, his
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