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upon which an estimate may be made. Vanicek v. Commissioner, 85
T.C. 731, 743 (1985).
Petitioner has not provided the Court with any evidence that
would allow us to make an estimate of his deductible expenses
under the Cohan rule. Therefore, we hold that he is not entitled
to itemized deductions for 1992 in excess of the standard
deduction allowed by respondent.
The second issue for decision is whether petitioner is
liable for the section 6662(a) accuracy-related penalty for 1992.
Respondent's determination of negligence is presumed to be
correct, and petitioner bears the burden of proving that the
penalty does not apply. Rule 142(a); Welch v. Helvering, 290
U.S. 111, 115 (1933); 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,
one of which is negligence or disregard of rules or regulations.
Sec. 6662(b)(1). Respondent determined that petitioner is liable
for the accuracy-related penalty imposed by section 6662(a) for
his underpayment of tax in 1992, and that such underpayment is
due to negligence or disregard of rules or regulations.
"Negligence" includes a failure to make a reasonable attempt to
comply with the provisions of the Internal Revenue laws or to
exercise ordinary and reasonable care in the preparation of a tax
return. Sec. 6662(c); sec. 1.6662-3(b)(1), Income Tax Regs.
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