Some facts have been deemed admitted under Tax Ct. R. Pract. & Proc. 91(f) and are so found. The Tinneys resided in Florida at the time the petition was filed. Travis Tinney was self-employed in the construction industry during 2006. Amanda Tinney, his wife, was a homemaker. The Tinneys filed a Form 1040, U.S. Individual Income Tax Return, for 2006. An accountant prepared the 2013 Tax Ct. Memo LEXIS 93">*95 return, which included a Schedule C and a Schedule A. The Tinneys did not review the return before signing it. The adjustments in the notice of deficiency are summarized in the table below.

The case was tried in Tampa, Florida.

One procedural matter requires attention before we proceed to the merits of this case. When the case was called for trial, Amanda Tinney did not appear, nor was there any appearance on her behalf. Travis Tinney did appear. As Travis Tinney had no authority to represent his wife, and there was no other appearance by her or on her behalf, the Court will, on its own motion, dismiss her from this *95 case for lack of prosecution. A decision will be entered against Amanda Tinney for a deficiency 2013 Tax Ct. Memo LEXIS 93">*96 and a penalty in the same amounts as those ultimately determined against Travis Tinney.

The taxpayer generally bears the burden of proving by a preponderance of the evidence that the IRS's determinations in the notice of deficiency are incorrect. Tax Ct. R. Pract. & Proc. 142(a); Welch v. Helvering, 290 U.S. 111">290 U.S. 111, 290 U.S. 111">115, 54 S. Ct. 8">54 S. Ct. 8, 78 L. Ed. 212">78 L. Ed. 212, 1933-2 C.B. 112 (1933); Bronstein v. Commissioner, 138 T.C. 382">138 T.C. 382, 138 T.C. 382">384 (2012). Under section 7491(a), if the taxpayer produces credible evidence with respect to any factual issue relevant to ascertaining the taxpayer's liability for tax and meets other requirements, the burden of proof rests on the IRS as to that factual issue. The Tinneys have not established their compliance with the requirements of section 7491(a). They bear the burden of proof with respect to the deficiency determined in the deficiency notice. SeeTax Ct. R. Prac. & Proc. 142(a).

The Tinneys attached a Schedule C to their 2006 return for Travis Tinney's construction business Travis Tinney operated. They reported gross receipts of *96 $24,100. The facts deemed established show that the Tinneys failed to report $101,963 in gross receipts. ^{22013 Tax Ct. Memo LEXIS 93">*97 2013 Tax Ct. Memo LEXIS 93">*98}

We hold that the Tinneys failed to report $101,963 in gross receipts for Travis Tinney's construction business.

On the Schedule C the Tinneys claimed deductions of $14,560 for car and truck expenses, $1,480 for insurance, and $4,945 for repairs and maintenance. These deductions—which total $20,985—related to an F-350 truck that Travis Tinney used for business purposes. According to the return, the $14,650 in the car *97 and truck category was equal to 32,720 miles multiplied by a business use percentage of 100%, multiplied by a standard mileage rate of 0.445 dollars per mile. The notice of deficiency allowed only a $12,289 deduction for the expenses for the F-350 truck, which was calculated using the mileage method. Thus, the notice of deficiency disallowed $2,271 of the $14,560 deduction the Tinneys claimed in the car and truck category, it completely disallowed the $1,480 deduction claimed for insurance, and it completely disallowed the $4,945 2013 Tax Ct. Memo LEXIS 93">*99 deduction claimed for repairs and maintenance. The total disallowance was $8,696 (= $2,271 + $1,480 + $4,945).

The Tinneys presented no documentary evidence or testimony regarding the disallowed F-350 truck expenses. Therefore they have not met their burden of proof. ³ We hold that they cannot deduct the $8,696 in disallowed expenses.

On their Schedule A, the Tinneys entered $33,644 as "other expenses" under miscellaneous itemized deductions. A statement attached to the Schedule A gave the following details:

At 2013 Tax Ct. Memo LEXIS 93">*100 trial Travis Tinney testified that the $33,644 was the total expense of repairing and rehabilitating rental properties that the Tinneys owned. One of these properties, Travis Tinney testified, was 1315 Florida Avenue in St. Cloud, Florida. ⁴ He introduced no documents to support the deductibility of the $33,644 in expenses.

*99 To the extent the $33,644 constitutes travel expenses, no deduction is available because there is no evidence corroborating Travis Tinney's testimony. Seesec. 274(d). As for the nontravel expenses, there is insufficient information on which to base an estimate of any deductible amount. Therefore, no deduction can be allowed for nontravel expenses. See Williams v. United States, 245 F.2d 559">245 F.2d 559, 245 F.2d 559">560 (5th Cir. 1957); Vanicek v. Commissioner, 85 T.C. 731">85 T.C. 731,85 T.C. 731">742-743 (1985).

The IRS determined that the Tinneys are liable for an accuracy-related penalty pursuant to section 6662(a) and 2013 Tax Ct. Memo LEXIS 93">*101 (b)(1) and (2) for negligence or substantial understatement of income tax. The IRS bears the burden of production with respect to this penalty. Seesec. 7491(c). To meet this burden, the IRS must produce evidence establishing that it is appropriate to impose this penalty. Once the IRS has done so, the burden of proof is upon the Tinneys. See Higbee v. Commissioner, 116 T.C. 438">116 T.C. 438, 116 T.C. 438">449 (2001). Negligence includes a failure to make a reasonable attempt to comply with internal revenue laws or to exercise ordinary and reasonable care in preparing a tax return. Seesec. 6662(c); sec. 1.6662-3(b)(1), Income Tax Regs. Negligence also includes the failure to keep adequate books and records or substantiate items properly. Seesec. 1.6662-3(b)(1), Income *100 Tax Regs. The Tinneys did not maintain adequate records of the disputed items, and they did not review the return before filing it. The IRS has carried its burden of production with respect to the section 6662(a) penalty for negligence. For the same reasons we conclude (1) there was no reasonable cause for the underpayment and (2) the Tinneys did not act in good faith. Seesec. 6664(c)(1) (the accuracy-related penalty does not apply with respect 2013 Tax Ct. Memo LEXIS 93">*102 to any underpayment for which it is shown that the taxpayer has reasonable cause and acted in good faith).

We hold that the Tinneys are liable for a section 6662(a) penalty for negligence.

To reflect the foregoing,

Decision will be entered under Rule 155 with respect to Travis C. Tinney, and an appropriate order and decision will be entered with respect to Amanda A. Tinney.