- 41 - often used interchangeably with compensation. Respondent did not disallow any part of petitioner’s compensation expense deduction. (4) Neither Steve, who had signed, nor Bedevian, who had prepared petitioner’s fiscal 1990 tax return, both of whom testified, provided us with evidence as to what were the intended components of petitioner’s claimed $101,517 rent expenses deduction. Based on the foregoing we conclude that petitioner has failed to persuade us that it is more likely than not that petitioner’s deductible rent expenses exceed $15,517. We hold for respondent on this issue. III. Section 6662 Respondent determined that petitioner is liable for an accuracy-related penalty for negligence in the amount of 20 percent of the entire underpayment. Respondent contends that “petitioner failed to exercise due care or do what a reasonable and ordinarily prudent person would do under the circumstances.” Alternatively, respondent contends that petitioner is liable for an accuracy-related penalty in the amount of 20 percent of the entire underpayment for substantial understatement of tax. Petitioner maintains that it has no deficiency and therefore is not liable for an accuracy-related penalty under section 6662. We agree with respondent.Page: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 Next
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