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maintain their landscaping business in California. We hold that
the costs of the airfare and meals cannot be deducted as ordinary
and necessary business expenses under section 162. Therefore, we
sustain respondent’s determination on this issue.
Accuracy-Related Penalty
Pursuant to section 6662(a), respondent determined that
petitioners are liable for an accuracy-related penalty due to an
underpayment of tax attributable to negligence or disregard of
rules or regulations. Because respondent determined that
petitioners had failed to report income, failed to maintain
proper records to substantiate the Schedule C deductions, and
deducted personal expenses, respondent computed the accuracy-
related penalty based upon the entire underpayment.
Petitioners bear the burden of proving that section 6662
does not apply. See Rule 142(a); Tweeddale v. Commissioner, 92
T.C. 501, 506 (1989). Petitioners have neither offered any
evidence regarding this issue nor provided a reasonable
explanation why we should not hold them liable for the accuracy-
related penalty. Accordingly, we sustain respondent’s
determination of the accuracy-related penalty with regard to the
underpayment associated with petitioners' concessions and this
Court's redeterminations.
In reaching our holdings herein, we have considered all of
petitioners’ arguments, and, to the extent not mentioned above,
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