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f. Whether Section 6662 Applies Only to Stamp Tax
Petitioner contends that section 6662 applies only to the
failure to pay a stamp tax. We disagree. The accuracy-related
penalty for negligence is not limited to failure to pay stamp
tax.
g. Conclusion as to Negligence
We conclude that petitioner did not have reasonable cause
for carrying forward NOLs from 1981-86 to the years in issue and
is liable for additions to tax for negligence for 1987-88 under
section 6653(a) and the accuracy-related penalty for negligence
for 1989-90 and 1992-97 under section 6662(a). In light of our
conclusion, we need not decide whether petitioner substantially
understated his tax liability for 1989-90 and 1992-97 for
purposes of section 6662(b)(2).
2. Failure To Timely File
A taxpayer is liable for an addition to tax of up to 25
percent for failure to timely file a Federal income tax return
unless the failure was due to reasonable cause and not willful
neglect. Sec. 6651(a)(1); United States v. Boyle, 469 U.S. 241,
245 (1985).
If section 7491(c) applies, respondent has met the burden of
production because, as stated at paragraph 3 of the findings of
fact, petitioner filed his returns late for 1987-90 and 1992.
Thus, petitioner is liable for the addition to tax for failure to
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