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otherwise, for medical care of the taxpayer. The deduction is
limited to expenses paid during the taxable year which exceed 7.5
percent of the taxpayer's adjusted gross income. Petitioner's
adjusted gross income limitation on her deduction for medical
expenses is $2,801.
Petitioner admitted at trial that the amount of her medical
expenses was overstated by $10,000 due to a clerical error. She
maintains, however, that she paid out-of-pocket medical expenses
of between $2,000 and $3,000 during 1992 for her prenatal and
postnatal care which were not covered by her medical insurance
through her job at Ryder Truck Rental. However, she did not
obtain any records which show what portions of her medical
expenses were paid by her insurance and herself. We find that
petitioner has failed to meet her burden of proof with regard to
her medical expenses. Rule 142(a). Respondent's determination
is sustained on this issue.
The seventh issue for decision is whether petitioner is
liable for the section 6662(a) accuracy-related penalties for
1992 and 1993. Respondent's determinations of negligence are
presumed to be correct, and petitioner bears the burden of
proving that the penalties do not apply. Rule 142(a); Welch v.
Helvering, 290 U.S. at 115; Bixby v. Commissioner, 58 T.C. 757,
791-792 (1972).
Section 6662(a) imposes a 20-percent penalty on the portion
of the underpayment attributable to any one of various factors,
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