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reported by petitioner's returns, which are stipulated in
evidence herein.
2. With respect to the itemized deductions (Schedule A) on
petitioner's return for the year 1992, respondent disallowed the
amount of $28,985 as deductions; petitioner, however, claimed
only $29,495 in itemized deductions on that return, of which
respondent has conceded $1,306. We know of no basis for
respondent's determination of a disallowed deduction in excess of
petitioner's claim, after allowing for respondent's concession.
3. With respect to the year 1993, respondent disallowed
$28,526 of itemized deductions; petitioner had claimed $29,870,
and after respondent's concession of $1,344, the net disallowance
by respondent of $28,526 appears correct in accordance with the
present record.
The above discrepancies with respect to the disallowances by
respondent as compared to the deductions as claimed by petitioner
in the 2 years in question will have to be reconciled in the
necessary computation herein under Rule 155.
With regard to the penalties in tax for the years 1992 and
1993, determined herein by respondent, section 6662(a) imposes a
penalty in the amount of 20 percent of the portion of the
underpayment attributable to negligence. Petitioner is liable
for an accuracy-related penalty for negligence in the preparation
and filing of his 1992 and 1993 tax returns. Petitioner failed
to substantiate any of the deductions taken on the 1992 and 1993
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