Karen L. Thorpe - Page 14

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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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