Agnes T. Bosco - Page 9

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          rendered.  Petitioner correctly included it as income on her                
          Federal tax return.  Had the cost of petitioner’s temporary                 
          lodging amounted to a qualified moving expense, her entitlement             
          to a deduction would not have been eliminated because Authentic             
          Fitness paid her a bonus described as a “Total Tax Liability                
          Gross-Up”.  Therefore, the payment to petitioner is income, and             
          that payment does not affect the character of the other payments            
          related to petitioner's move.                                               
               Respondent determined a section 6662(a) penalty against                
          petitioner in the amount of $741.12.  Section 6662(a) provides              
          for a 20-percent penalty for any underpayment to which the                  
          section applies.  Respondent determined that section 6662(b)                
          applied to petitioner because petitioner was negligent or                   
          disregarded rules or regulations.                                           
               Negligence is defined as “any failure to make a reasonable             
          attempt to comply with the provisions of this title.”  Disregard            
          includes “careless, reckless, or intentional disregard”.  Sec.              
          6662(c).  Although respondent bears the burden of production                
          under section 7491(c), petitioner must still show she had                   
          reasonable cause to believe her deduction was correct.  The Court           
          holds that petitioner was negligent in claiming part of her                 
          moving expenses as deductible.                                              
               Petitioner filed her 2001 Federal income tax return on April           
          10, 2002.  She received a letter on or about February 10, 2002,             
          from Warnaco explaining the items on her Form W-2.  The expense             






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