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among other means of transportation, the use of any passenger
automobile. Sec. 280F(d)(4)(A)(i) and (ii). Petitioner
presented no documentation, other than the log and other receipts
referred to above, to document the use of his vehicle for local
transportation in connection with his employment. Respondent,
therefore, is also sustained with respect to those expenses.
Petitioner also claimed other expenses incurred in his
employment for a telephone and a pager. He presented no evidence
to establish the amount claimed for such expenses. Consequently,
no amount is allowed to petitioner for such expenses.
Petitioner also claimed a deduction of $700 for tax
preparation fees on his 1999 return. Although he presented no
evidence to establish payment of that amount, with the
disallowance of the other claimed miscellaneous expenses, the
claimed $700 would be less than 2 percent of petitioner's
adjusted gross income for 1999. Therefore, petitioner would
realize no tax benefit therefrom because of the section 67(a)
limitation.
The third issue is the applicability of the accuracy-related
penalties under section 6662(a) determined against petitioner for
the 2 years at issue. Petitioner contended that he should be
exonerated from these penalties because he relied on his return
preparer.
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