Melvin L. Levinson - Page 5




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          failed to present sufficient evidence to establish that                     
          respondent's determinations are incorrect.  See Welch v.                    
          Helvering, 290 U.S. 111, 115 (1933).  Accordingly, respondent's             
          determinations are sustained.                                               
               Respondent determined that petitioner is liable for section            
          6662(a) accuracy-related penalties for failing to pay self-                 
          employment tax and failing to substantiate deductions relating to           
          petitioner's patents.  The penalty applies to the portion of                
          petitioner's underpayment that is attributable to negligence or             
          disregard of the rules or regulations.  Sec. 6662(b)(1).                    
          Petitioner is not liable for self-employment tax, and he acted in           
          good faith and had reasonable cause for claiming the disallowed             
          deductions.  See sec. 1.6664-4(a), Income Tax Regs.  At trial,              
          petitioner failed to substantiate a portion of the expenses he              
          deducted on his return.  At the time he filed his return,                   
          however, he made reasonable efforts to determine the                        
          deductibility of these expenses (e.g., he relied on his records,            
          conducted tax research, and attended tax seminars).  Accordingly,           
          petitioner is not liable for the accuracy-related penalties.                
               Contentions we have not addressed are irrelevant, moot, or             
          meritless.                                                                  










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