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46017 (Nov. 6, 1985). Sec. 1.274(d)-1(a), Income Tax Regs. The
standard business mileage rate for transportation expenses paid
or incurred on or after January 1, 1996, is 31 cents per mile for
all miles of use for business purposes. Rev. Proc. 95-54, 1995-2
C.B. 450, 452.
Petitioner produced a copy of her daily appointment book
that reflects approximately 17,300 business miles traveled in
1996 to substantiate her claim. We are satisfied that petitioner
has provided credible evidence substantiating the number of
business miles traveled, and petitioner is allowed a deduction of
$5,249.23 (31 cents times 16,933).
8. Section 6662 Accuracy-Related Penalty
The accuracy-related penalty is equal to 20 percent of any
portion of an underpayment of tax required to be shown on the
return that is attributable to, among other things, the
taxpayer’s negligence or disregard of rules or regulations or any
substantial understatement of income tax. Sec. 6662(a) and (b).
“Negligence” includes any failure to make a reasonable attempt to
comply with the provisions of the Code and any failure by the
taxpayer to keep adequate books and records or to substantiate
items properly. Sec. 6662(c); sec. 1.6662-3(b)(1), Income Tax
Regs. “Disregard” includes any careless, reckless, or
intentional disregard. Sec. 6662(c). A taxpayer has a
substantial understatement of income tax if the amount of the
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