Gary Wilson - Page 2




                                        - 2 -                                         
                                                       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