Julie Pusateri - Page 9

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               Petitioner conceded that she took deductions on both the               
          Schedule C-1 and the Schedule E which were false.  She had no               
          right to claim these deductions.  She was unable to substantiate            
          many of the deductions she claimed on both the Schedule C-1 and             
          the Schedule C-2.  In fact, she only fully substantiated two                
          items originally deducted on the two Schedules C.  Petitioner               
          filed a false Schedule E that benefited her through the avoidance           
          of self-employment tax.                                                     
               Under the foregoing circumstances, we can only conclude that           
          she was negligent.  We find that petitioner is liable for the               
          accuracy-related penalty.                                                   
               To reflect the various adjustments,                                    
                                                  Decision will be entered            
                                             under Rule 155.                          

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