- 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