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Freuhauf vans, trailer, and the canopy, were used in petitioner’s
business. Accordingly, depreciation deductions relating to these
items are allowed.
III. Negligence
Section 6662(a) and (b)(1) impose an accuracy-related
penalty on the portion of an underpayment of tax attributable to
negligence. Petitioner contends that no tax deficiency exists
and blames his accountant for errors and omissions on his tax
returns. We are unpersuaded. Petitioner overstated his
deductions, underreported income, failed to report his rental
activities, filed as single instead of married, failed to review
the return, and had no reasonable cause for any of these errors.
Petitioner did not exercise due care in the filing of his return
and thus is liable for the section 6662(a) penalty.
Contentions we have not addressed are moot, irrelevant, or
meritless.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011