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with reasonable cause or in good faith is made on a case-by-case
basis. Sec. 1.6664-4(b)(1), Income Tax Regs. Isolated
computational or transcriptional errors are not inconsistent with
reasonable cause and good faith. Id.
Generally, with respect to the portion of the understatement
attributable to petitioner's disallowed charitable contribution
deductions, petitioner's errors did not rise to the level of
negligence. With few exceptions, petitioner substantiated the
deductions claimed. The disallowance of many of the deductions
turned on the resolution of a difficult factual question, such as
valuation, reasonableness, or the meaning of "personal pleasure,
recreation, or vacation".
Despite our general finding, we conclude that petitioner was
negligent with respect to certain items deducted as charitable
contributions. The "sleep or rest rule" is well settled law.
Accordingly, we conclude petitioner carelessly disregarded the
rules and regulations by deducting $25 for meal expenses on a 1-
day trip in violation of this rule. The prohibition on the
deduction of personal expenses is equally well settled. We again
conclude petitioner carelessly disregarded the rules and
regulations by deducting personal expenses. This finding relates
to petitioner's deductions for gratuities and taxes attributable
to spa services and the extra tank of gasoline, discussed above.
We exclude from this finding the $100 petitioner paid for an auto
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