Nathaniel L. Ward, Sr. and Irene E. Ward - Page 9

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          expenses for 1992 and 1993 in the amounts of $612.20 and $834.47,           
          respectively.                                                               
               Regarding the remainder of the deduction for employment-               
          related expenditures, we have taken into consideration the                  
          totality of the circumstances, including payments in one year               
          that would likely have been paid in other years in connection               
          with their teaching activities.  Accordingly, and relying on                
          Cohan v. Commissioner, supra at 543-544, we find that petitioners           
          are entitled to $1,0005 of employee business expenses, in                   
          addition to the amounts allowed in connection with the computers,           
          all of which are subject to any computational limitations for               
          each of the taxable years 1992 and 1993.                                    
               Respondent determined an accuracy-related penalty due to               
          negligence under section 6662(a) for petitioners' 1992 and 1993             
          taxable years.  The accuracy-related penalty is equal to 20                 
          percent of any portion of an underpayment attributable to a                 
          taxpayer's negligence or disregard of rules or regulations.  Sec.           
          6662(a) and (b)(1).  The term "negligence" includes any failure             
          to do what a reasonable and ordinarily prudent person would do              
          under the same circumstances.  Neely v. Commissioner, 85 T.C.               
          934, 947 (1985).  The term "disregard" includes any careless,               
          reckless, or intentional disregard.  Sec. 6662(c).  The penalty             
          does not apply to any portion of an underpayment for which there            


               5 This amount includes the $771.92 documentation of union              
          dues that respondent conceded for 1993.                                     



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