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penalty) increase in tax for the 1995 tax year.
Petitioner offered no evidence on this adjustment and makes
no argument that would show that respondent’s determination is in
error. Accordingly, we hold that petitioner is liable for the
$130 increase in tax and that respondent’s reclassification of
the $1,300 from wage to pension income is sustained.
Finally, we consider whether petitioner is liable for an
accuracy-related penalty for failing to report the bonuses
received during 1993, 1994, or 1995.4 Respondent determined that
section 6662(a) applies and that petitioner is liable for a 20-
percent accuracy-related penalty on the portion of the
underpayment represented by the failure of petitioner to report
her bonuses for 1993, 1994, or 1995.
A taxpayer is negligent when he or she fails “‘to do what
[a] reasonable and ordinarily prudent person would do under the
circumstances.’” Korshin v. Commissioner, 91 F.3d 670, 672 (4th
Cir. 1996) (quoting Schrum v. Commissioner, 33 F.3d 426, 437 (4th
Cir. 1994), affg. in part, vacating and remanding in part on
another ground T.C. Memo. 1993-124), affg. T.C. Memo. 1995-46.
As pertinent here, “negligence” includes the failure to make
a reasonable attempt to comply with the provisions of the
4 As a result of the inclusion of the bonuses in income some
purely mathematical adjustments resulted due to an increase in
petitioner’s adjusted gross income, which, in turn, caused a
reduction in allowable itemized deductions.
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