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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 a
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