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We find that the medical and job expenses were not
substantiated, except for the $315 amount respondent conceded.
This amount has no net tax effect because of the 7.5 percent of
adjusted gross income limitation under section 213(a). We also
find that the job expenses were not ordinary and necessary to
petitioner’s job as a shift supervisor. Sec. 162(a).
Accordingly, we sustain respondent’s determinations as to these
issues.
Respondent determined that petitioners were liable for the
section 6662(a) penalty in the amount of $462. Section 6662(a)
provides for an accuracy-related penalty in the amount of 20
percent of the portion of an underpayment of tax attributable to,
among other things, negligence or disregard of rules or
regulations. Sec. 6662(a) and (b)(1). Negligence is defined to
include any failure to make a reasonable attempt to comply with
the provisions of the Internal Revenue laws and any failure by
the taxpayer to keep adequate books and records or to
substantiate items properly. Sec. 6662(c); sec. 1.6662-3(b)(1),
Income Tax Regs.
Petitioners provided no records which substantiated their
alleged expenses, aside from the amounts of dental expenses
substantiated, minor in amount compared to the amounts
petitioners claimed as deductions. Nor did they attempt to
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