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the years at issue. On that record, we further find that peti-
tioner has failed to carry his burden of showing that he was 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 the underpayment for each of
those years.4 On the record before us, we also find that peti-
tioner has failed to carry his burden of establishing that he
acted with reasonable care and in good faith with respect to the
underpayment for each of the years at issue.5 See sec.
6664(c)(1). On that record, we further find that petitioner has
failed to carry his burden of showing that he is not liable for
each of the years at issue for the accuracy-related penalty under
section 6662(a).
We have considered all of the contentions and arguments of
petitioner that are not discussed herein, and we find them to be
without merit and/or irrelevant.
To reflect the foregoing and the concessions of the parties,
Decision will be entered
under Rule 155.
4Petitioner did not maintain any records to substantiate
that he is entitled to deduct for each of the years at issue
claimed Schedule C expenses in excess of the amount conceded by
respondent. See sec. 1.6662-3(b)(1), Income Tax Regs.
5See supra note 4.
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