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evidence regarding these expenses; therefore, we hold for
respondent on this issue.
Respondent also determined an accuracy-related penalty under
section 6662(a), which imposes an addition to tax in the amount
of 20 percent of any underpayment attributable to negligence. To
avoid this negligence penalty, petitioner has the burden of
showing that his actions were not careless, reckless, or made
with intentional disregard of rules or regulations. See Delaney
v. Commissioner, 743 F.2d 670 (9th Cir. 1984), affg. T.C. Memo.
1982-666. Because petitioner has presented no evidence as to why
his actions were reasonable, petitioners are liable for the
section 6662 penalty for the taxable year 1990. See Lyszkowski
v. Commissioner, T.C. Memo. 1995-235, affd. 79 F.3d 1138 (3d Cir.
1996). In addition, petitioner’s allegations that respondent’s
actions were improper do not constitute reasonable cause.
Respondent also determined that petitioners were subject to
an addition to tax for failure to timely file a tax return. This
addition is imposed by section 6651(a)(1) unless petitioner can
show that the late filing was due to reasonable cause. See Bixby
v. Commissioner, 58 T.C. 757 (1972). Petitioner has offered no
evidence to show that respondent’s determination of the addition
to tax was in error. Accordingly, petitioners are liable for the
section 6651(a)(1) addition to tax for their 1990 tax year.
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