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we also agree with respondent that petitioner has not met
his burden of proving entitlement to the deduction. See
Rule 142(a), Tax Court Rules of Practice and Procedure.
Petitioner does not cite the section of the Internal
Revenue Code under which he claims to be entitled to the
deduction. See generally secs. 217, 132(a)(6), (g), 82.
Moreover, as described above, he refers to relocation
expenses, but he never explains the nature of the expenses
that he incurred, or identifies the payees, amounts, or
dates of any such payments, nor has he introduced proof
that he paid any such expenses.
Accuracy-Related Penalty for 1991
The next issue for decision is whether petitioner is
liable for the accuracy-related penalty under section
6662(a), as determined by respondent in the amount of $475.
According to the schedules attached to the notice of
deficiency, respondent determined that the entire amount
of the underpayment was due to negligence. Under section
6662, a penalty is added to a taxpayer's tax liability if
any portion of an underpayment is attributable to
negligence or disregard of rules or regulations. See sec.
6662(b)(1). For this purpose, the term "negligence"
includes any failure to make a reasonable attempt to comply
with the provisions of the Internal Revenue Code. Sec.
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