Christopher Wagner - Page 10




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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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