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taxpayer in a manner that is arbitrary and capricious. In
Hamacher v. Commissioner, supra at 354, the Court recited the
background for the enactment of section 280A's restriction upon
deduction of home office expenses and pointed out that one of the
reasons for the enactment of section 280A was a response by
Congress to numerous cases, particularly those decided by this
Court, which used a liberal standard to allow deduction of home
office expenses that were "appropriate and helpful" to the
taxpayer's business under the circumstances. Congress was
concerned that, under such a standard, personal, living, and
family expenses attributable to the home that are not otherwise
deductible were being allowed as deductions. The purpose of
section 280A was to restrict what Congress considered too liberal
a standard in this area of tax law. The restrictive provisions
of section 280A, therefore, apply to all taxpayers. The Court,
therefore, rejects petitioners' contention that section
280A(c)(1) violates the Due Process Clause of the Fifth
Amendment.
Respondent determined that petitioners were liable for
penalties under section 6662(a) for negligence or disregard of
rules or regulations under section 6662(b)(1).
Section 6662(a) provides that, if it is applicable to any
portion of an underpayment in taxes, there shall be added to the
tax an amount equal to 20 percent of the portion of the
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