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We sustain respondent's determination on this issue.5
Although petitioner asks us to allow him some deductions to
offset this income, we decline to do so. Petitioner must prove
his entitlement to any deduction, and he must keep sufficient
records to substantiate any deduction that he claims. Sec. 6001;
New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934).
Petitioner has not introduced any evidence to substantiate his
entitlement to any deductions, and the record does not persuade
us that petitioner is entitled to any deductions.
Respondent also determined that petitioner was liable for an
accuracy-related penalty under section 6662(a) because he
substantially understated his Federal income tax. See sec.
6662(b)(2). As relevant herein, section 6662(a) imposes an
accuracy-related penalty equal to 20 percent of an underpayment
that is due to a substantial understatement of income tax.
Petitioner will avoid this penalty if the record shows that his
income tax was not understated by the greater of 10 percent of
the tax required to be shown on the return or $5,000. Sec.
6662(d)(1)(A). The accuracy-related penalty of section 6662 is
not applicable to any portion of an underpayment to the extent
that an individual has reasonable cause for that portion and acts
in good faith with respect thereto. Sec. 6664(c)(1). Such a
determination is made by taking into account all facts and
5 Petitioner has not challenged respondent's determination
that this income is subject to self-employment tax. We sustain
that determination without further comment. See Rule 142.
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