Carol Anderson - Page 9

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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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