Barry and Penny Knelman - Page 8




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          maintain their landscaping business in California.  We hold that              
          the costs of the airfare and meals cannot be deducted as ordinary             
          and necessary business expenses under section 162.  Therefore, we             
          sustain respondent’s determination on this issue.                             
          Accuracy-Related Penalty                                                      
               Pursuant to section 6662(a), respondent determined that                  
          petitioners are liable for an accuracy-related penalty due to an              
          underpayment of tax attributable to negligence or disregard of                
          rules or regulations.  Because respondent determined that                     
          petitioners had failed to report income, failed to maintain                   
          proper records to substantiate the Schedule C deductions, and                 
          deducted personal expenses, respondent computed the accuracy-                 
          related penalty based upon the entire underpayment.                           
               Petitioners bear the burden of proving that section 6662                 
          does not apply.  See Rule 142(a); Tweeddale v. Commissioner, 92               
          T.C. 501, 506 (1989).  Petitioners have neither offered any                   
          evidence regarding this issue nor provided a reasonable                       
          explanation why we should not hold them liable for the accuracy-              
          related penalty.  Accordingly, we sustain respondent’s                        
          determination of the accuracy-related penalty with regard to the              
          underpayment associated with petitioners' concessions and this                
          Court's redeterminations.                                                     
               In reaching our holdings herein, we have considered all of               
          petitioners’ arguments, and, to the extent not mentioned above,               






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