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sec. 301.6223(g)-1T(b)(1)(iv), Temporary Proced. & Admin. Regs.,
52 Fed. Reg. 6786 (Mar. 5, 1987); sec. 301.6224(c)-3T(c),
Temporary Proced. & Admin. Regs., supra.
II. Additions To Tax Under Section 6653(a)
The second issue we must address is whether petitioners are
liable for additions to tax for negligence for the taxable years
before us.
Petitioners’ underpayments for the taxable years were fixed
in conjunction with Jojoba’s stipulation to be bound to our
decision in Utah Jojoba I Research v. Commissioner, T.C. Memo.
1998-6. Section 6653 provides, in relevant part, that if any
part of any underpayment is due to negligence, there shall be
added to the tax (1) an amount equal to 5 percent of the
underpayment and (2) an amount equal to 50 percent of the
interest payable under section 6601 with respect to the portion
of such underpayment which is attributable to negligence and for
the period beginning on the last date prescribed by law for
payment of such underpayment and ending on the date of the
assessment of the tax. Sec. 6653(a)(1) and (2) (for taxable
years 1982, 1983, and 1985); sec. 6653(a)(1)(A) and (B) (for
taxable year 1986). Respondent determined that all of
petitioners’ underpayments were attributable to negligence.
Petitioners contend they reasonably relied on professionals,
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