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expenses, a record of a business purpose and relationship for
these items is conspicuously absent. Furthermore, petitioner's
testimony in this regard was vague and unhelpful. Thus, we find
that, other than as allowed by respondent, petitioner has failed
to substantiate the deductions claimed for car transportation,
parking, meals and entertainment, and gifts, as required by
section 274 and the regulations thereunder.
We also find that, although a deduction for tax preparation
fees is generally available to taxpayers under section 212,
petitioner has failed to present any evidence to corroborate the
deduction claimed for such an expense on her Schedule A.
Section 6662(a) Penalty
Respondent determined an accuracy-related penalty under
section 6662(a) with respect to petitioner's 1991 Federal income
tax return for negligence or disregard of rules or regulations.
In pertinent part, section 6662 imposes an accuracy-related
penalty equal to 20 percent of the portion of an underpayment of
tax that is attributable to negligence or disregard of rules or
regulations. Sec. 6662(a), (c). Section 6662(c) defines
"negligence" as including any failure to make a reasonable
attempt to comply with the provisions of the Internal Revenue
Code, and defines "disregard" as including any careless,
reckless, or intentional disregard.
Petitioner failed to offer any evidence to rebut
respondent's determination of an accuracy-related penalty in this
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