- 18 - Petitioners acknowledge their failure to keep adequate records in support of their claimed deductions for expenditures subject to the substantiation requirements of section 274(d), e.g., travel and entertainment expenses (including meals with clients), and they concede that the accuracy-related penalty applies to any underpayment attributable to deduction disallowances with respect to such expenditures. They argue, however, that they made “a good-faith attempt to maintain proper documentation in accordance with applicable rules and regulations” as regards the other section 162 expenses, and that the penalty should not apply to any underpayment attributable to the disallowance of deductions attributable to those expenses. We note that petitioners have conceded all or a portion of every deduction challenged by respondent, not merely the deductions subject to section 274(d). Moreover, we have found that petitioners’ records fail to sustain a large portion of the deductions remaining in issue. Under those circumstances, we sustain the negligence penalty for the whole of petitioners’ underpayment of tax. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18
Last modified: May 25, 2011