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portion of an underpayment of tax attributable to, among other
things, negligence or disregard of rules or regulations. Sec.
6662(a) and (b)(1). Negligence is defined to include any failure
to make a reasonable attempt to comply with the provisions of the
internal revenue laws and any failure by the taxpayer to keep
adequate books and records or to substantiate items properly.
Sec. 6662(c); sec. 1.6662-3(b)(1), Income Tax Regs.
Petitioner failed to substantiate the expenses she deducted
on her Schedule C. Accordingly, we sustain respondent's
determination as to the section 6662(a) penalty.
To the extent that we have not addressed any of petitioner's
arguments, we have considered them and conclude that they are
without merit.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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Last modified: May 25, 2011