Richard Clarke Randall - Page 6

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               Here, we conclude that respondent has met his burden of                
          production with respect to the accuracy-related penalty.                    
          Petitioner’s amended return for 2003 shows total tax due of zero.           
          Thus, the deficiency in this case, which is greater than $5,000,            
          is a substantial understatement within the meaning of section               
          6662(d).  In addition, the deficiency in this case is                       
          attributable to negligence as defined in section 6662(c), as                
          petitioner has failed to make any reasonable attempt to comply              
          with the provisions of the Internal Revenue Code.  In that                  
          petitioner has introduced no evidence to support a finding of               
          reasonable cause, we sustain respondent’s determination as to the           
          accuracy-related penalty.                                                   
               To reflect the foregoing,                                              
                                             Decision will be entered                 
                                             for respondent.                          

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