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With respect to the disallowance of miscellaneous deductions
pertaining to 1995, petitioners have the burden of establishing
that they are entitled to the deductions claimed. Rule 142;
INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992). After
this Court rejected the argument that wages were not income,
petitioner was given ample opportunity to present argument and
evidence disputing respondent's determinations. Petitioner
refused. We, therefore, sustain respondent's determinations.
Respondent determined that petitioners are liable for an
accuracy-related penalty under section 6662(a) for 1995 for
negligence. Section 6662(a) provides that "there shall be added
to the tax an amount equal to 20 percent of the portion of the
underpayment to which this section applies." Section 6662
applies to "the portion of any underpayment which is attributable
to", inter alia, negligence or disregard of the rules or
regulations. Sec. 6662(b)(1). Negligence "includes any failure
to make a reasonable attempt to comply with the provisions * * *
[of the Internal Revenue Code], and the term 'disregard' includes
any careless, reckless, or intentional disregard." Sec. 6662(c).
Petitioners again have the burden of establishing that the
determination of the penalty was erroneous. Tweeddale v.
Commissioner, 92 T.C. 501, 505 (1989). Petitioners presented no
evidence or argument concerning respondent's determination.
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