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made on his home on behalf of Currie, his “agent”. This expense
appears to be the kind of personal expenditure that is
nondeductible under section 262.
Finally, as to the professional development and maintenance
expenses, petitioner presented no documentation or testimony to
support these deductions, and he seems to have abandoned his
claim for these items. As to the claimed telephone expenses, the
only evidence of telephone expenses presented were telephone
charges appearing on the hotel bills incurred while petitioner
was on tour with the band. There is no evidence that these calls
were business related, and, hence, petitioner is not entitled to
any deduction.
Accuracy-Related Penalty Under Section 6662
We finally consider whether petitioner is liable for the
section 6662 accuracy-related penalty. Section 6662 imposes a
penalty equal to 20 percent of the portion of the underpayment
attributable to, inter alia, negligence or disregard of rules or
regulations. "Negligence" includes failure to make a reasonable
attempt to comply with the law, and the term "disregard" includes
careless, reckless, or intentional disregard. Sec. 6662(c).
Failure to maintain adequate records constitutes negligence.
Crocker v. Commissioner, 92 T.C. 899, 917 (1989); Schroeder v.
Commissioner, 40 T.C. 30, 34 (1963).
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