Lisa B. Williams - Page 12

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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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