Janet Phillips - Page 5

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          Commissioner, 85 T.C. 934, 947 (1985) (quoting Marcello v                   
          Commissioner, 380 F.2d 499, 506 (5th Cir. 1967), affg. in part              
          and remanding in part 43 T.C. 168 (1964)).  Petitioner has failed           
          to establish that she exercised due care in reporting her income            
          and expenses, Bixby v. Commissioner, 58 T.C. 757, 791 (1972), or            
          that she acted with reasonable cause and in good faith, sec.                
          6664(c).  Accordingly, petitioner is liable for the section 6662            
          accuracy-related penalties.                                                 
               All other arguments raised by the parties are either                   
          irrelevant or without merit.                                                
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             for respondent.                          






















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