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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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