- 19 - H. Other Expenses With respect to the remaining expenses claimed on petitioners’ Schedule C and disallowed by respondent, we hold that petitioners have failed to substantiate these deductions. The only other evidence in the record consists of miscellaneous receipts, many of which provide no information regarding the subject of the underlying transaction or the parties thereto. Many others are from restaurants (e.g., McDonald’s, Taco Bell, Sizzler), gas stations, and grocery stores. A significant portion are obviously for nondeductible personal expenditures. Moreover, to the extent that they might relate to the claimed travel, meal, and vehicle expenses, the receipts fall far short of the strict substantiation requirements of section 274. We sustain respondent’s position as to all remaining expenses not previously addressed. III. Accuracy-Related Penalty Subsection (a) of section 6662 imposes an accuracy-related penalty in the amount of 20 percent of any underpayment that is attributable to causes specified in subsection (b). Subsection (b) of section 6662 then provides that among the causes justifying imposition of the penalty are: (1) Negligence or disregard of rules or regulations and (2) any substantial understatement of income tax.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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