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cleaners in the amount of $900, and car washes in the amount of
$350. Respondent disallowed the $800 for tolls and half of the
$1,200, or $600, for parking because respondent contends that
they were reimbursed by Excel. However, respondent allowed $500
for uniforms and cleaners. The parties stipulated that
petitioners are entitled to deduct the entire $350 for car
washes.
On this record, we find that petitioners are not entitled to
deduct expenses for tolls, parking, and uniforms and cleaners in
excess of the amount allowed by respondent. In addition to
failing to provide any receipts to evidence the expenditures for
tolls and parking, we note that the president of Excel stated
that Excel reimburses its drivers for all tolls. Further,
petitioners failed to provide any receipts, canceled checks, or
credit card statements to evidence the claimed expenditures for
uniforms and cleaners in excess of those allowed by respondent.
Accuracy-related penalty
Finally, we must decide whether petitioners are liable for
an accuracy-related penalty. Section 6662(a) imposes an
accuracy-related penalty in the amount of 20 percent of the
portion of an underpayment of tax attributable to negligence or
disregard of rules or regulations. Sec. 6662(a) and (b)(1).
Negligence is any failure to make a reasonable attempt to comply
with the provisions of the Internal Revenue laws. Sec. 6662(c);
sec. 1.6662-3(b)(1), Income Tax Regs. Moreover, negligence is
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