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of tips earned by petitioner during his daily shifts. As
previously stated, petitioner did not keep a tip diary of the
cash received from the cashier. Also, petitioner did not report
these cash distributions to the Hilton or on his returns filed
for taxable year 2000. Petitioner has failed to provide any
evidence to controvert respondent’s determination as to
petitioner’s unreported tip income for taxable year 2000. He
simply presented this Court with frivolous contentions that merit
no further discussion. See Rowlee v. Commissioner, 80 T.C. 1111
(1983); Hallock v. Commissioner, T.C. Memo. 1983-684. Thus, we
sustain respondent’s determination on this issue, as modified by
respondent’s position at trial.
2. Accuracy-Related Penalty
As previously stated, respondent, in the notice of
deficiency, determined that petitioner is liable for the
accuracy-related penalty pursuant to section 6662(a) and (b)(1)
for the taxable year 2000.
Section 6662(a) provides for an accuracy-related penalty of
20 percent of the portion of any underpayment attributable to,
among other things, negligence or intentional disregard of rules
or regulations. Sec. 6662(b)(1). The term “negligence” is the
failure to make a reasonable attempt to comply with the
provisions of the Internal Revenue Code, or the failure to do
what a reasonable and ordinarily prudent person would do under
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