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majority of expenses she deducted on her Schedules C for 1993 and
1994. Petitioner had many years of experience in auditing and
accounting. Although she retained Mr. Baker to prepare her tax
returns, petitioner does not assert, and we do not find, that she
could reasonably rely on the advice of Mr. Baker as a basis for
not maintaining and keeping records to substantiate her inventory
balances or various business expense items. Therefore, we
sustain respondent's determination and hold that petitioner is
liable for the accuracy-related penalties.
Decisions will be entered
under Rule 155.
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Last modified: May 25, 2011