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to his trade or business rather than primarily personal in
nature. Accordingly, on this record, the Court holds that
petitioner is not entitled to the Schedule C deduction for
travel, meals, and entertainment expenses.
The final issue is whether petitioner is liable for the
accuracy-related penalty under section 6662(a) for negligence or
disregard of rules or regulations. Section 6662(a) provides
that, if it is applicable to any portion of an underpayment in
taxes, there shall be added to the tax an amount equal to 20
percent of the portion of the underpayment to which section 6662
applies. Section 6662(b)(1) provides that section 6662 shall
apply to any underpayment attributable to negligence or disregard
of rules or regulations.
Section 6662(c) provides that the term "negligence" includes
any failure to make a reasonable attempt to comply with the
provisions of the Internal Revenue laws, and the term "disregard"
includes any careless, reckless, or intentional disregard of
rules or regulations. Negligence is the lack of due care or
failure to do what a reasonable and ordinarily prudent person
would do under the circumstances and includes any failure to keep
adequate books and records or to substantiate items properly.
Neely v. Commissioner, 85 T.C. 934, 947 (1985); sec. 1.6662-
3(b)(1), Income Tax Regs.
However, under section 6664(c), no penalty shall be imposed
under section 6662(a) with respect to any portion of an
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