Steven K. Stoddard and Ellen M. Stoddard - Page 31

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          person would do under the circumstances.  Leuhsler v. Commis-               
          sioner, 963 F.2d 907, 910 (6th Cir. 1992), affg. T.C. Memo. 1991-           
          179; Antonides v. Commissioner, 91 T.C. 686, 699 (1988), affd.              
          893 F.2d 656 (4th Cir. 1990).  An understatement is equal to the            
          excess of the amount of tax required to be shown in the tax                 
          return over the amount of tax shown in the tax return, sec.                 
          6662(d)(2)(A), and is substantial in the case of an individual if           
          it exceeds the greater of 10 percent of the tax required to be              
          shown or $5,000, sec. 6662(d)(1)(A).                                        
               The accuracy-related penalty under section 6662(a) does not            
          apply to any portion of an underpayment if it is shown that there           
          was reasonable cause for, and that the taxpayer acted in good               
          faith with respect to, such portion.  Sec. 6664(c)(1).                      
               The only evidence that petitioners introduced in support of            
          their position that they were not negligent was Ms. Stoddard’s              
          testimony.  We found her testimony to be general, conclusory,               
          and/or uncorroborated in certain material respects, and we shall            
          not rely on it to establish petitioners’ position that respondent           
          erred in determining to impose the accuracy-related penalty under           
          section 6662(a) for each of the years at issue.  On the record              
          before us, we find that petitioners have failed to show that they           
          were not negligent and did not disregard rules or regulations               
          within the meaning of section 6662(b)(1), or otherwise did what a           
          reasonable person would do, with respect to any portion of the              

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