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1993 taxable year. We therefore have jurisdiction to determine
whether petitioner is liable for the addition to tax under
section 6654(a).
Unless a statutory exception applies, the addition to tax
under section 6654(a) is mandatory. Sec. 6654(a), (e); Recklitis
v. Commissioner, 91 T.C. 874, 913 (1988); Grosshandler v.
Commissioner, 75 T.C. 1, 20-21 (1980); Estate of Ruben v.
Commissioner, 33 T.C. 1071, 1072 (1960). None of the statutory
exceptions under section 6654(e) applies in this case. Nor has
petitioner presented any arguments regarding this issue. We
sustain respondent’s determination.
7. Accuracy-Related Penalties
Respondent determined petitioner is liable for accuracy-
related penalties under section 6662(a) for 1995, 1996, and 1997.
The accuracy-related penalty is equal to 20 percent of any
portion of an underpayment of tax required to be shown on the
return that is attributable to the taxpayer’s negligence or
disregard of rules or regulations. Sec. 6662(a) and (b)(1).
“Negligence” consists of any failure to make a reasonable attempt
to comply with the provisions of the Internal Revenue Code and
also includes any failure to keep adequate books and records or
to substantiate items properly. Sec. 6662(c); 1.6662-3(b)(1),
Income Tax Regs. “Disregard” consists of any careless, reckless,
or intentional disregard. Sec. 6662(c).
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