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Petitioner did not have any receipts for expenses in excess
of the $75 respondent allowed for the cellular telephone or the
$75 in postage, and accordingly, we sustain respondent with
respect to these matters.
With respect to her draft amended 2000 Schedule C,
petitioner did not introduce any documentation except a bill from
her tax return preparer in the amount of $408. As with her 1999
return, we hold that she is entitled to deduct half of that bill
on her Schedule C for the cost of preparing her 2000 Schedule C.
In addition, because of the lack of any further substantiation
and because of petitioner’s concessions, we sustain respondent’s
determination of petitioner’s receipts.1
3. Accuracy-Related Penalties
Section 6662 provides that a taxpayer may be liable for a
penalty of 20 percent of the portion of an underpayment of tax
due to negligence or disregard of rules or regulations.
“Negligence” is defined as any failure to make a reasonable
1 Petitioner conceded the claim for education credits set
forth on her tax return for 2000. During the hearing of this
case, petitioner conceded her claim for education expense
deductions for 2000, and that concession negates any claim for
education credits. In any event petitioner is not entitled to a
Hope Scholarship Credit under sec. 25A(b) because she failed to
show or even allege that she was a half-time student for any
portion of 2000. Sec. 25A(b)(2)(B) and (3). Petitioner is not
entitled to a Lifetime Learning Credit for 2000 because she
failed to show that during 2000 she paid “qualified tuition and
related expenses” within the meaning of sec. 25A(c)(1) and as
defined in sec. 25A(f)(1).
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