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Petitioners presented no evidence that they purchased any
clothing or shoes that were used by petitioner in his employment
that was not adaptable to personal use. The Court recognizes
that petitioner was required to wear at work a "bunny", an
apparel over his regular clothing, which more than likely would
not be suitable for ordinary wear. However, petitioner presented
no evidence that he was required to purchase or did in fact
purchase such clothing. The inference from the record is that
such clothing was provided by petitioner's employer. On this
record, petitioners have not established their entitlement to a
deduction for unreimbursed employee expenses. The concessions by
respondent relate to tax preparation fees, subject to the
limitations of section 67(a). Respondent, therefore, is
sustained in the disallowance of the itemized deductions at
issue, except as to the amounts allowed by the Court and
respondent's concessions.
The second issue is whether petitioners should be held
liable for the section 6662(a) penalties. Petitioners contend
they should be absolved of liability for such penalties because
they relied on the representations of their return preparer, Mr.
Beltran.
Section 6662(a) provides for an accuracy-related penalty
equal to 20 percent of any portion of an underpayment of tax
required to be shown on the return that is attributable to the
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