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that he or she meets one of the exceptions provided in section
6654(e), none of which apply here. Petitioner offered no
evidence to show why she did not pay estimated tax. We conclude
that petitioner is liable for the addition to tax for failure to
pay estimated tax under section 6654 for 1993.
E. Whether Petitioner Is Liable for the Accuracy-Related
Penalty for 1994
Respondent contends that petitioner is liable for the
accuracy-related penalty for negligence under section 6662(a) for
1994. Taxpayers are liable for a penalty equal to 20 percent of
the part of the underpayment attributable to negligence or
disregard of rules or regulations. Sec. 6662(a) and (b)(1).
Negligence includes failure to make a reasonable attempt to
comply with internal revenue laws or to exercise ordinary and
reasonable care in preparing a tax return. Sec. 6662(c).
Petitioner bears the burden of proving that she is not liable for
the accuracy-related penalty. Rule 142(a); Tweeddale v.
Commissioner, 92 T.C. 501, 505 (1989).
Petitioner made no argument and offered no evidence that she
is not liable for the accuracy-related penalty. We conclude that
petitioner is liable for the accuracy-related penalty for 1994.
To reflect the foregoing,
Decision will be
entered for respondent.
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