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for an accuracy-related penalty pursuant to section 6662(a) for
the year in issue. Section 6662(a) imposes a penalty of 20
percent of the portion of the underpayment which is attributable
to negligence or disregard of rules or regulations. Sec.
6662(b)(1). Negligence is the “‘lack of due care or failure to
do what a reasonable and ordinarily prudent person would do under
the circumstances.’” Neely v. Commissioner, 85 T.C. 934, 947
(1985) (quoting Marcello v. Commissioner, 380 F.2d 499, 506 (5th
Cir. 1967), affg. in part and remanding in part on another issue
43 T.C. 168 (1964) and T.C. Memo. 1964-299). It includes any
failure by the taxpayer to keep adequate books and records or to
substantiate items properly. Sec. 1.6662-3(b)(1), Income Tax
Regs. The term “disregard” includes any careless, reckless, or
intentional disregard. Sec. 6662(c). No penalty shall be
imposed if it is shown that there was reasonable cause for the
underpayment and the taxpayer acted in good faith with respect to
the underpayment. Sec. 6664(c).
At trial, petitioner testified that her accountant prepared
her 1997 return based on receipts and “all kinds of stuff” she
brought to him. Although petitioner purportedly provided
documentation to her accountant, it remains her responsibility to
provide information necessary to accurately prepare her return
and to review the return prior to filing. Moreover, her claim
that she provided adequate documentation to her accountant is
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