- 9 -
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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Last modified: May 25, 2011