- 30 - 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 autoPage: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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