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Niedringhaus v. Commissioner, 99 T.C. 202, 219 (1992); Tokarski
v. Commissioner, 87 T.C. 74, 77 (1986).
The Court finds that elements of personal pleasure,
recreation, or vacation constituted a significant element of
petitioner’s trip. The Court concludes that section 170(j)
prohibits a deduction for the traveling expenses incurred on his
trip to England and Wales. Accordingly, respondent is sustained
on this issue to the extent not conceded by him.
C. Accuracy-Related Penalty
Under section 7491(c), the Commissioner has the burden of
production in any court proceeding with respect to the liability
of any individual for any penalty or addition to tax. Higbee v.
Commissioner, 116 T.C. at 446-447. In order to meet his burden
of production, the Commissioner must come forward with sufficient
evidence indicating that it is appropriate to impose the
accuracy-related penalty. Id. at 446. Once the Commissioner
meets his burden of production, the taxpayer bears the burden of
proving that the Commissioner’s determination is incorrect. Id.
at 446-447.
Respondent determined that petitioner is liable for the
accuracy-related penalty under section 6662(a). Section 6662(a)
imposes a 20-percent penalty on the portion of an understatement
attributable to any one of various factors, including negligence
or disregard of rules or regulations and a substantial
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