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auto mileage based on their initial reconstructions submitted at
the time of the audit. Petitioners' ever increasing claims for
additional mileage are unsubstantiated. This issue was not
addressed by petitioners on brief. Deductions are a matter of
legislative grace; petitioners have the burden of showing that
they are entitled to any deduction claimed. New Colonial Ice Co.
v. Helvering, 292 U.S. 435, 440 (1934). We find that petitioners
have not proven that they are entitled to mileage expenses in
excess of those allowed by respondent.
C. Section 6662(a) Accuracy-Related Penalty
Section 6662(a) imposes a penalty in an amount equal to 20
percent of the portion of the underpayment of tax attributable to
one or more of the items set forth in section 6662(b), such as
negligence or disregard of rules or regulations. Respondent
determined that the entire underpayment of petitioners' tax was
due to negligence or intentional disregard of rules or
regulations. Sec. 6662(b)(1). As in the case of the predecessor
section covering the addition to tax for negligence, section
6653(a), petitioners bear the burden of proof on the penalties in
issue. Rule 142(a); Neely v. Commissioner, 85 T.C. 934, 947
(1985). Negligence includes a failure to make a reasonable
attempt to comply with the provisions of the internal revenue
laws. Sec. 6662(c); sec. 1.6662-3(b)(1), Income Tax Regs.
Negligence is the failure to exercise due care or the failure to
do what a reasonable and prudent person would do under the
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