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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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