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failure to file was due to reasonable cause and not due to
willful neglect. Accordingly, we hold that petitioner is liable
for additions to tax under section 6651(a)(1) for the years 1993
and 1995 in the amounts of $794.25 and $389.75, respectively.
Respondent contends that petitioner is also liable for the
section 6662(a) penalty. Section 6662(a) provides for an
accuracy-related penalty in the amount of 20 percent of the
portion of an underpayment of tax attributable to, among other
things, negligence or disregard of rules or regulations. Sec.
6662(a) and (b)(1). Negligence is defined to include any failure
to make a reasonable attempt to comply with the provisions of the
Internal Revenue laws, and also includes any failure by the
taxpayer to keep adequate books and records, or to substantiate
items properly. Sec. 6662(c); sec. 1.6662-3(b)(1), Income Tax
Regs. Moreover, negligence is the failure to exercise due care
or the failure to do what a reasonable and prudent person would
do under the circumstances. Neely v. Commissioner, 85 T.C. 934,
947 (1985). Disregard is defined to include any careless,
reckless, or intentional disregard of rules or regulations. Sec.
6662(c); sec. 1.6662-3(b)(2), Income Tax Regs.
Petitioner did not provide any substantiation at trial for
the deductions he claimed. He did not maintain adequate records
as required under section 6001. We find that respondent
established that petitioner was negligent and that he disregarded
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