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tacitly approved petitioner’s methodology, respondent has come
forward with sufficient evidence to prove petitioner’s
negligence. Petitioner did not maintain a contemporaneous
mileage log for the claimed mileage deductions. Petitioner
claimed deductions for the occasional motel he stayed in when he
did not feel like driving back to his recreational vehicle or
apartment. However, petitioner failed to offer any receipts or
explain how he calculated these expenses. Petitioner claimed
deductions for flights between Idaho and California, and the
associated parking expenses, but failed to proffer this Court any
records, receipts, or reconstruction for submission into
evidence.
The most important factor in deciding whether a taxpayer was
negligent is the extent of the taxpayer’s efforts to determine
the proper tax liability. Sec. 1.6664-4(b), Income Tax Regs. In
light of the many deductions petitioner claimed, his failure to
maintain adequate records was not a reasonable attempt to comply
with the Internal Revenue Code. We therefore sustain
respondent’s position.
In addition to the accuracy-related penalties for 1992 and
1993, respondent determined an addition to tax pursuant to
section 6651(a) for late filing for 1993. The addition is 5
percent of the amount required to be shown as tax on the
delinquent return for each month the return is late (not to
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