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Respondent determined a deficiency of $9,500 in petitioner’s
2000 Federal income tax and an accuracy-related penalty of
$1,897. After concessions by petitioner of many items of
unreported income, this Court must decide: (1) Whether
petitioner may deduct unreimbursed partnership expenses which
were not claimed on his individual income tax return, and (2)
whether petitioner is liable for the accuracy-related penalty
under section 6662(a).
Some of the facts in this case have been stipulated and are
so found. Petitioner resided in Glendale, California, at the
time he filed his petition.
Because petitioner has not complied with the substantiation
requirements of section 7491(a)(2), the burden of proof as to
facts relevant to the deficiency remains on petitioner. Rule
142(a). Petitioner also has the burden of proof as to liability
for the penalty, although respondent has the initial burden of
production with respect to its applicability. Sec. 7491(c);
Higbee v. Commissioner, 116 T.C. 438, 446-447 (2001).
During taxable year 2000, petitioner was a general partner
in the partnership Hines & Hunt Entertainment (Hines & Hunt).
Hines & Hunt was in the business of entertainment management.
Petitioner was a personal manager and represented actors and
actresses.
For taxable year 2000, Hines & Hunt filed a Form 1065, U.S.
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Last modified: May 25, 2011