- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011