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existed for his late filing. Petitioner claims constant transit
and relocations as his reasonable cause for late filing. We are
not convinced by this argument. Thus, with no evidence probative
of reasonable cause, we conclude that petitioner is liable under
section 6651(a)(1) for additions to tax for failure to timely
file his Federal income tax returns for 1998, 1999, and 2000.
VI. Accuracy-Related Penalties
Respondent also determined that petitioner is liable under
section 6662(a) for accuracy-related penalties for tax years 1998
and 1999. Section 6662(a) imposes an accuracy-related penalty
equal to 20 percent of the underpayment to which section 6662
applies. Section 6662 applies to the portion of an underpayment
of tax which is attributable to, among other things, negligence
or intentional disregard of rules or regulations, a substantial
understatement of income tax, or a substantial valuation
misstatement. See sec. 6662(b)(1)-(3). Section 6662(c) defines
“negligence” as “any careless, reckless, or intentional
disregard.” See also Hansen v. Commissioner, 820 F.2d 1464, 1469
(9th Cir. 1987) (“Intentional disregard occurs when a taxpayer
who knows or should know of a rule or regulation chooses to
ignore the requirements.”).
Section 6664(c)(1) provides that the accuracy-related
penalty shall not be imposed with respect to any portion of an
underpayment if it is shown that there was reasonable cause for
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