- 7 - accorded her a corresponding income tax deduction in the amount of $888. Respondent further determined that petitioner was liable for additions to tax and penalties arising from her 1993 and 1994 returns. For 1993, respondent determined that petitioner owed $1,373 pursuant to section 6651(a)(1) for failure to file a timely return, and $1,958 pursuant to section 6662(a) as an accuracy-related penalty. For 1994, respondent determined that petitioner owed $1,375 pursuant to section 6662(a) as an accuracy-related penalty.1 OPINION Disallowed Deductions Mileage The largest deductions claimed by petitioner on her Schedule C's for the years in issue were $13,160 for mileage driven in 1993 and $13,050 for mileage driven in 1994. Respondent determined that petitioner failed to substantiate her mileage deductions as required by section 274(d) and, therefore, limited the deduction to $4,000 for mileage for each of the years in issue. Subject to respondent's concessions, we sustain respondent's determination for 1993 in toto. For 1994, we sustain respondent's determination only in part. 1 In addition, respondent determined that petitioner owed, pursuant to sec. 6654, $275 in 1993 and $175 in 1994 for failure to pay estimated taxes. Because petitioner filed income tax returns for both years this Court has no jurisdiction and does not consider these additions to tax. See sec. 6665(b)(2).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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