14
ending balance was $634. However, there is no evidence
indicating the charges for which the beginning balance of $517
was derived. A statement dated November 15, 1992, shows a
balance forward of $634, new uniform charges of $100.18, and an
ending balance of $734. A statement dated March 15, 1993, shows
a balance forward of $734, other charges of $15, and an ending
balance of $749. Petitioner has only established that he charged
uniforms in the amount of $217. Petitioner testified that he
paid the balance on his account by the end of 1993 because he
stopped working for Delta at that time. Based on the record,
petitioner has established that he purchased uniforms at a cost
of $217, and he is entitled to a deduction for unreimbursed
employee expenses in this amount subject to the 2-percent floor.
Accuracy-Related Penalty
Respondent determined that petitioner is liable for an
accuracy-related penalty for negligence and disregard of rules or
regulations under section 6662(a). Petitioner bears the burden
of proving that respondent's determination is erroneous. Rule
142(a); Bixby v. Commissioner, 58 T.C. 757, 791 (1972).
Section 6662(a) imposes an accuracy-related penalty equal to
20 percent of the portion of any underpayment of tax that is due
to negligence or disregard of rules or regulations. Sec. 6662(a)
and (b)(1). "Negligence" is any failure to make a reasonable
attempt to comply with the provisions of the Internal Revenue
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