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Petitioner has not offered any explanation for her delinquency.
Petitioner has engaged in a lengthy and consistent pattern of
failing timely to file income tax returns. See Hastings v.
Commissioner, T.C. Memo. 1999-167. We therefore hold that
petitioner is liable for the section 6651(a)(1) addition to tax
for the 1993 taxable year.
IV. Section 6662(a) Accuracy-Related Penalty
Respondent determined that petitioner is liable for the
accuracy-related penalty under section 6662(a) for 1993.
Subsection (a) of section 6662 imposes a penalty in an amount
equal to 20 percent of the portion of any underpayment of tax
attributable to causes specified in subsection (b). Subsection
(b) of section 6662 then provides that among the causes
justifying imposition of the penalty are: (1) Negligence or
disregard of rules or regulations and (2) any substantial
understatement of tax.
“Negligence” is “any failure to make a reasonable attempt to
comply with the provisions of this title”, and “disregard” is
“any careless, reckless, or intentional disregard.” Sec.
6662(c). An understatement is equal to the excess of the amount
of tax required to be shown on the return less the amount of tax
shown on the return. Sec. 6662(d)(2)(A). In the case of an
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