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preparation because the totals were merely copied onto the
matching lines of the Schedule C. The scratch pads were
carelessly prepared in petitioner's admitted haste to complete
his tax return.
Petitioner's carelessness also caused him to fail to
properly allocate the personal use portion of expenses for
utilities, home mortgage interest, vehicle insurance, car and
truck expenses, and property taxes.
Furthermore, petitioner's carelessness caused him to claim
both depreciation and the rental expenses for the leased van.
In our judgment petitioner's conduct was neither reasonable
nor prudent. His numerous errors are due to his failure to keep
accurate records and to verify the correct amount of his business
expenses. Therefore, we conclude that respondent's imposition of
the section 6662(a) penalty for negligence was justified.
To reflect the concessions made by respondent and our
conclusions with respect to the disputed issues,
Decision will be entered
under Rule 155.
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