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conclusory, and/or uncorroborated in certain material respects,
and we shall not rely on it. On the record before us, we find
that petitioners have failed to carry their burden of showing
that during 1996 they paid $4,454.03 of mortgage interest in
addition to the $17,392 conceded by respondent.
Based upon our examination of the entire record before us,
we find that petitioners have failed to carry their burden of
proving that they are entitled to a mortgage interest deduction
in excess of the $17,392 conceded by respondent.
Accuracy-Related Penalty
Respondent determined that petitioners are liable for each
of the years at issue for the accuracy-related penalty under
section 6662(a) because of: (1) Negligence under section
6662(b)(1) or (2) a substantial understatement of income tax
under section 6662(b)(2).
Section 6662(a) imposes an accuracy-related penalty equal to
20 percent of the underpayment of tax resulting from, inter alia,
negligence or disregard of rules or regulations, sec. 6662(b)(1),
or a substantial understatement of income tax, sec. 6662(b)(2).
For purposes of section 6662(a), the term “negligence” includes
any failure to make a reasonable attempt to comply with the Code,
and the term “disregard” includes any careless, reckless, or
intentional disregard. Sec. 6662(c). Negligence has also been
defined as a lack of care or failure to do what a reasonable
17(...continued)
Doon Way residence.
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