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substantiating the amount and purpose of the deductions claimed.
See Hradesky v. Commissioner, 65 T.C. 87, 90 (1975), affd. per
curiam 540 F.2d 821 (5th Cir. 1976); sec. 1.6001-1(a), Income Tax
Regs. Moreover, taxpayers are required to maintain records that
are sufficient to enable the Commissioner to determine their
correct tax liability. See sec. 6001; Meneguzzo v. Commissioner,
43 T.C. 824, 831-832 (1965); sec. 1.6001-1(a), Income Tax Regs.
Therefore, we hold that petitioner is not entitled to claim
miscellaneous itemized deductions in excess of the amount
conceded by respondent.
Section 6662(a) imposes a penalty of 20 percent of the
portion of the underpayment which is attributable to negligence
or disregard of rules or regulations. See sec. 6662(b)(1).
Negligence is the lack of due care or failure to do what a
reasonable and ordinarily prudent person would do under the
circumstances. See Neely v. Commissioner, 85 T.C. 934, 947
(1985). The term "disregard" includes any careless, reckless, or
intentional disregard. Sec. 6662(c). No penalty shall be
imposed if it is shown that there was reasonable cause for the
underpayment and the taxpayer acted in good faith with respect to
the underpayment. See sec. 6664(c).
On the basis of the record, we find that petitioner has
failed to demonstrate that he was not negligent and also has
failed to show that he did not disregard rules and regulations.
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