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Commissioner, supra at 446-447. Section 6662(a) imposes an
accuracy-related penalty in the amount of 20 percent of the
portion of the underpayment of tax attributable to negligence or
disregard of rules or regulations. See sec. 6662(b)(1).
Negligence is any failure to make a reasonable attempt to comply
with the provisions of the internal revenue laws. See sec.
6662(c); sec. 1.6662-3(b)(1), Income Tax Regs. Moreover,
negligence is the failure to exercise due care or the failure to
do what a reasonable and prudent person would do under the
circumstances. Neely v. Commissioner, 85 T.C. 934, 947 (1985).
Disregard includes any careless, reckless, or intentional
disregard of rules or regulations. See sec. 6662(c); sec.
1.6662-3(b)(2), Income Tax Regs. No penalty will be imposed with
respect to any portion of an underpayment if it is shown that
there was reasonable cause for such portion and that the taxpayer
acted in good faith with respect to such portion. See sec.
6664(c).
On the basis of the record, we conclude that petitioner is
liable for the accuracy-related penalties under section 6662(a).
Petitioner claimed various deductions totaling $41,853 for 1997
and 1998, failed to report $80 of interest income for 1998, and
filed as a head of household for 1998. Petitioner has not shown
that he acted in good faith in claiming or not reporting these
amounts. Respondent has met his burden of production under
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