- 11 - for his pro se appearances. Petitioner is claiming a deduction for his loss of time or the value thereof, and he is not entitled to it. Accordingly, respondent’s determination is sustained. II. Accuracy-Related Penalty Initially, the Commissioner has the burden of production with respect to any penalty, addition to tax, or additional amount. Sec. 7491(c). The Commissioner satisfies this burden of production by coming forward with sufficient evidence that indicates that it is appropriate to impose the penalty. See Higbee v. Commissioner, 116 T.C. 438, 446 (2001). Once the Commissioner satisfies this burden of production, the taxpayer must persuade the Court that the Commissioner’s determination is in error by supplying sufficient evidence of reasonable cause, substantial authority, or a similar provision. Id. In pertinent part, section 6662(a) imposes an accuracy-related penalty equal to 20 percent of the underpayment that is attributable to: (1) Negligence or disregard of the rules or regulations; or (2) a substantial understatement of income tax. Section 6662(c) defines the term “negligence” to include “any failure to make a reasonable attempt to comply with the provisions of this title”, and the term “disregard” to include “any careless, reckless, or intentional disregard.” In interpreting section 6662, this Court has defined the term “negligence” as a “‘lack of due care or the failure to do what aPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 NextLast modified: November 10, 2007