- 9 -
related penalty is inapplicable.1 See Rule 142(a); Welch v.
Helvering, supra at 115; Bixby v. Commissioner, 58 T.C. 757, 791-
792 (1972).
With respect to the cable charges, petitioners claimed
business deductions for expenses which were personal in nature.
Petitioners have failed to provide any information about the
business purpose of their claimed travel and meal and
entertainment expenses.
Accordingly, we hold that petitioners are liable for an
accuracy-related penalty pursuant to section 6662(a) with respect
to the understatement of tax attributable to the deductions we
have disallowed.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
under Rule 155.
1 Section 7491(c), applicable to court proceedings arising
in connection with examinations commencing after July 22, 1998,
requires the Secretary to carry the burden of production with
respect to additions to tax. See Internal Revenue Service
Restructuring & Reform Act of 1998, Pub. L. 105-206, sec. 3001,
112 Stat. 726. Petitioners do not contend that their examination
commenced after July 22, 1998, or that sec. 7491 is applicable to
them.
Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011