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there is nothing in the record to support petitioners’ position
and, moreover, there is no authority that supports such
treatment.
We agree with respondent. There is no indication in the
record as to which of the “Other Expenses” listed on the
attachment to line 46 of Schedule C actually relate to Randall’s
wages from Wells Fargo Bank or which expenses petitioners
actually intended to transfer from the Schedule C to the Schedule
A. At a minimum, petitioners must show that the deductions
disallowed by respondent were among the expenses transferred to
the Schedule A, which they have not done. We, therefore, reject
petitioners’ request to treat any portion of respondent’s
deduction disallowance sustained herein as a reduction of
petitioners’ itemized deductions on the Schedule A.
III. Accuracy-Related Penalty
Section 6662 provides for an accuracy-related penalty (the
accuracy-related penalty) in the amount of 20 percent of the
portion of any underpayment attributable to, among other things,
negligence or intentional disregard of rules or regulations
(without distinction, negligence), any substantial understatement
of income tax, or any substantial valuation misstatement.
Respondent determined the accuracy-related penalty against
5(...continued)
total miscellaneous itemized deductions in excess of 2 percent of
adjusted gross income due to the reduction in that number.
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