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and Ms. Brodsky are liable for each of the years at issue for the
accuracy-related penalty under section 6662(a) because of negli-
gence or disregard of rules or regulations under section
6662(b)(1).
In the 1993 notice, respondent determined that petitioner
and Ms. Brodsky are liable for 1993 for the addition to tax under
section 6651(a)(1) because they did not timely file their 1993
joint return and did not show that that failure was due to
reasonable cause.
Amendment to Answer and Reply to that Amendment
On October 7, 1999, the Court had filed respondent’s amend-
ment to answer, which respondent had lodged on September 24,
1999, when respondent filed a motion for leave to file amendment
to answer. Respondent affirmatively alleged in the amendment to
answer, inter alia, that, in addition to the amount of the cost
of goods sold claimed in the 1993 Schedule C and disallowed in
the notice for 1993, petitioner is not entitled for that year to
$42,913 of the remaining amount of the cost of goods sold claimed
in that Schedule C.
On October 7, 1999, petitioner submitted a document entitled
“NOTICE OF OBJECTION”, in which petitioner replied to certain
affirmative allegations in respondent’s amendment to answer. The
Court had that document filed as a reply to the amendment to
answer (petitioner’s reply to respondent’s amendment to answer).
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