Adolfo and Maria Bedoy - Page 7




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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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