14 ending balance was $634. However, there is no evidence indicating the charges for which the beginning balance of $517 was derived. A statement dated November 15, 1992, shows a balance forward of $634, new uniform charges of $100.18, and an ending balance of $734. A statement dated March 15, 1993, shows a balance forward of $734, other charges of $15, and an ending balance of $749. Petitioner has only established that he charged uniforms in the amount of $217. Petitioner testified that he paid the balance on his account by the end of 1993 because he stopped working for Delta at that time. Based on the record, petitioner has established that he purchased uniforms at a cost of $217, and he is entitled to a deduction for unreimbursed employee expenses in this amount subject to the 2-percent floor. Accuracy-Related Penalty Respondent determined that petitioner is liable for an accuracy-related penalty for negligence and disregard of rules or regulations under section 6662(a). Petitioner bears the burden of proving that respondent's determination is erroneous. Rule 142(a); Bixby v. Commissioner, 58 T.C. 757, 791 (1972). Section 6662(a) imposes an accuracy-related penalty equal to 20 percent of the portion of any underpayment of tax that is due to negligence or disregard of rules or regulations. Sec. 6662(a) and (b)(1). "Negligence" is any failure to make a reasonable attempt to comply with the provisions of the Internal RevenuePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011