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petitioner’s figures, approximately three fifths of the total
amount that he paid for interviews was deducted as business
expenses. Although the Court disallows any part of these
interview expenses, we find that petitioner’s allocation might
well apply in determining the portion of his travel expenses
attributable to business. Accordingly, for 1993 and 1994, we
allow petitioner to deduct three fifth of his claimed travel
expenses (including meals and lodging) under section 274(d). We
sustain respondent’s disallowance of the claimed deductions to
the extent of two fifths thereof.
Finally, under section 6662, respondent determined that
petitioner was liable for a negligence penalty for 1993 and a
substantial understatement of income tax penalty for 1994. As
relevant herein, section 6662(a) imposes an accuracy-related
penalty equal to 20 percent of any underpayment that is
attributable to negligence or a substantial understatement of
income tax. An underpayment for purposes of this section is
essentially the same as a deficiency. Compare sec. 6664(a) with
sec. 6211(a). Although the instant case presents many issues,
the only one giving rise to respondent's determination of
penalties under section 6662 relates to whether petitioner
properly deducted expenses that he incurred while writing books.
Negligence under section 6662 is the lack of due care or
failure to do what a reasonable and ordinarily prudent person
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