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interests in mind. The fact remains, however, that petitioners
failed to establish how the expenses at issue were directly
related to either petitioner’s trade or business of earning
income as an educator, and were, in certain instances, explicitly
not deductible by operation of statute. See sec. 274(a)(3),
(m)(2); sec. 1.274-2(a)(2)(iii)(a), Income Tax Regs. Petitioners
also did not consult a professional tax advisor. While
apparently motivated by a desire to enhance the education of
their students, petitioners have failed to show reasonable cause
for the underpayment caused by petitioners’ claimed expenses. We
therefore sustain respondent's determination regarding the
accuracy-related penalty under section 6662(a).
To reflect the concessions of the parties,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011