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financial planning; (5) $986 for cell phone; (6) $169 for
parking; (7) $829 for professional business expenses; (8) $1,002
for prospecting green fees; and (9) $2,772 for teaching expenses.
Petitioner reported tax liability of $10,071 on his 2000 return.
Petitioner’s occupation is listed on the return as “SERV
TECH”, and the majority of his reported wage, salaries, tips,
etc., income for the year was from Lucent Technologies. Elray
Wise of E.W. Holding Co., is listed as the paid preparer of the
tax return.3
Respondent issued to petitioner a notice of deficiency dated
July 15, 2002, for the taxable year 2000. Respondent determined
that petitioner’s corrected tax liability was $28,930 and that he
was liable for additional tax of $1,156 under section 72(t). One
of respondent’s determinations was that petitioner was not
entitled to the claimed Schedule C expenses. Respondent
calculated that the underpayment of tax attributable to the
disallowed Schedule C expenses was $18,299. Finally, respondent
determined that petitioner was liable for an accuracy-related
penalty under section 6662(a) of 20 percent of the underpayment
attributable to the disallowed Schedule C expenses. Petitioner
timely filed a petition to this Court seeking a redetermination.
3The evidence in the record indicates that Robin Manasseh,
who worked for E.W. Holding Co., actually prepared petitioner’s
2000 tax return.
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