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Accuracy-related
Addition to Tax Penalty
Year Deficiency Sec. 6651(a)(1) Sec. 6662(a)
1992 $5,642 -- $1,128
1993 5,146 $519 1,029
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years at issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure. Respondent’s determination in the notice of
deficiency is presumed correct, and petitioner bears the burden
of proving that it is incorrect. Rule 142(a).1 The issues for
decision2 are whether petitioner (1) properly claimed deductions
for travel expenses, (2) properly claimed deductions for
miscellaneous business expenses, and (3) is liable for accuracy-
related penalties and an addition to tax under sections 6662(a)
and 6651(a), respectively. We sustain respondent’s
determinations, except that we allow some deductions in amounts
less than claimed by petitioner for miscellaneous business
expenses, resulting in reductions to the deficiencies, to be
given effect in the Rule 155 computation.
1Sec. 7491 does not apply because respondent’s examination
was commenced before July 23, 1998.
2 Petitioner presented no evidence to rebut respondent’s
determinations that petitioner failed to report unemployment
compensation and interest income in 1993. Respondent’s
determinations are sustained.
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Last modified: May 25, 2011