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Shea v. Commissioner, 112 T.C. 183, 189 (1999). On the instant
record, we find that petitioner did not maintain the records
required by section 6001 and section 1.6001-1(a), Income Tax
Regs. On that record, we further find that any unidentified
records that petitioner may have maintained were not adequate
under those provisions. On the instant record, we find that the
burden of production that respondent has under section 7491(c) is
satisfied. See sec. 1.6662-3(b)(1) and (2), Income Tax Regs.
Except for the testimony quoted above, petitioner presented
no evidence, and made no argument, with respect to the accuracy-
related penalty under section 6662(a) that respondent determined
for petitioner’s taxable year 1999. On the instant record, we
find that petitioner has failed to carry his burden of showing
that he was not negligent and did not disregard rules or regula-
tions, or otherwise did what a reasonable person would do, with
respect to the underpayment for that year.
On the instant record, we further find that petitioner has
failed to carry his burden of showing that there was reasonable
cause for, and that he acted in good faith with respect to, the
underpayment for the year at issue. See sec. 6664(c)(1).
On the record before us, we find that petitioner has failed
to carry his burden of establishing that he is not liable for
1999 for the accuracy-related penalty under section 6662(a).
We have considered all of the parties’ contentions and
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