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return on October 18, 2000. At that point, they had ample time
before the due date of the 1999 return in which to file that
return as well. Furthermore, we reject petitioners’ assertion
that they should be relieved of the addition to tax under section
6651(a)(1) because they did not receive the Form 1099-R from
Norwest or because they did not think that the filing of that
return was “an urgent matter”.
Imposition of the Accuracy-Related Penalty Under Section 6662(a)
With Respect to Petitioners’ 1999 Return
Respondent determined petitioners’ liability for the
accuracy-related penalty under section 6662(a) to be $12,793.13.
Respondent determined that a portion of the underpayment of tax
required to be shown on petitioners’ 1999 return is attributable
to negligence or disregard of rules or regulations, or to a
substantial understatement of income tax. See sec. 6662(b)(1)
and (2). For this purpose, “the term ‘negligence’ includes any
failure to make a reasonable attempt to comply with the
provisions of this title, and the term ‘disregard’ includes any
careless, reckless, or intentional disregard.” Sec. 6662(c). An
understatement of income tax is “substantial” if the amount of
the understatement exceeds the greater of (a) 10 percent of the
tax required to be shown on the return, or (b) $5,000. Sec.
6662(d)(1)(A).
We agree with respondent that the portion of the
underpayment of tax on which respondent imposed the accuracy-
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