Jefferry Phuong Vo and Mai Xuan Nguyen - Page 9




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          transport the generator system, and to travel to different                  
          locations to distribute brochures about their business.                     
          Respondent did not challenge petitioners’ substantiation of these           
          expenses, and nothing in the record contradicts petitioner’s                
          testimony.                                                                  
               We find that petitioners are not entitled to deductions for            
          $340 of utility expenses.  These expenses were incurred for cable           
          television.  Petitioner testified that the cable was necessary              
          because he liked to watch the news.  These expenses are personal            
          and not attributable to petitioners’ business.  We also find that           
          petitioners are not entitled to deductions for travel and meal              
          and entertainment expenses as petitioners have provided no                  
          evidence that these expenses were related to their business.                
               Finally, we address the accuracy-related penalty imposed               
          pursuant to section 6662(a).  Section 6662(a) and (b)(1) imposes            
          a penalty on any portion of an underpayment that is attributable            
          to negligence or disregard of rules or regulations.  The term               
          “negligence” includes any failure to make a reasonable attempt to           
          comply with the statute, and the term “disregard” includes any              
          careless, reckless, or intentional disregard.  Sec. 6662(c).  The           
          penalty does not apply to any portion of an underpayment for                
          which there was reasonable cause and with respect to which the              
          taxpayer acted in good faith.  See sec. 6664(c).                            
               Petitioners bear the burden of proving that the accuracy-              






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