Randall and Lynn Bishop - Page 16




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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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