- 10 - misunderstanding of fact or law that is reasonable in light of the experience, knowledge and education of the taxpayer." In these circumstances, we believe that petitioner's use of a per diem method to calculate his lodging expenses was an "honest misunderstanding" constituting reasonable cause under section 6664(c)(1). Thus, the underpayments arising from the disallowed travel expenses are not subject to accuracy-related penalties under section 6662(b)(1) or (2). Employee Benefit Program Petitioner has conceded that he is not entitled to a $1,086 deduction claimed on Schedule C of his 1990 return for employee benefit programs. Respondent contends that the amount represents petitioner's medical expenses that were not deductible on Schedule A because they did not exceed 7.5 percent of adjusted gross income, see sec. 213(a), and asserts that a section 6662(b)(1) penalty is appropriate because the deduction had no basis in law or fact. Petitioner offered no explanation or argument with respect to the deduction or the penalty. On this record, we find that the underpayment arising from this disallowed deduction is subject to the accuracy-related penalty under section 6662(b)(1). 1990 Interest Expense On Schedule C of his 1990 return, petitioner claimed interest expenses of $10,603 for "Mortgage" and $10,210 for "Other". With respect to the first amount, petitioner nowPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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