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application of the law by agents of the IRS. See Estate of
Emerson v. Commissioner, 67 T.C. 612, 617-618 (1977); Automobile
Club of Michigan v. Commissioner, 353 U.S. 180 (1957). The
Court, therefore, rejects petitioner's argument and holds that
petitioner's deductions for meals for the years 1995 and 1996 are
not deductible. Respondent is sustained on this issue.
Respondent determined that petitioner was liable for the
accuracy-related penalty under section 6662(a) for negligence or
disregard of rules or regulations under section 6662(b)(1).
Section 6662(a) provides that, if it is applicable to any
portion of an underpayment in taxes, there shall be added to the
tax an amount equal to 20 percent of the portion of the
underpayment to which section 6662 applies. Under section
6664(c), no penalty shall be imposed under section 6662(a) with
respect to any portion of an underpayment if it is shown that
there was a reasonable cause for such portion, and that the
taxpayer acted in good faith with respect to such portion.
Section 6662(b)(1) provides that section 6662 shall apply to
any underpayment attributable to negligence or disregard of rules
or regulations. Section 6662(c) provides that the term
"negligence" includes any failure to make a reasonable attempt to
comply with the provisions of the internal revenue laws, and the
term "disregard" includes any careless, reckless, or intentional
disregard of rules or regulations. Negligence is the lack of due
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