Mary Ann Tobin - Page 3




                                         -3-                                          
               3.   Whether petitioner is liable for the accuracy-related             
          penalty for negligence under section 6662(c) for 1990 and 1991.             
          We hold that she is not.2                                                   
                                I.  FINDINGS OF FACT                                  
               Some of the facts have been stipulated and are so found.               
          A.   Petitioner                                                             
               Petitioner has lived in Irvington, Kentucky, since 1941                
          (including when she filed her petition), and on a farm since                
          1969.                                                                       
               Petitioner graduated from the University of Kentucky with a            
          degree in accounting.  Petitioner was a Kentucky State                      
          representative from 1976 to the beginning of 1984.  She was                 
          Kentucky State auditor from 1984 to January 1988.  Petitioner ran           
          for the Kentucky State Senate in 1992 but lost in the general               
          election.  Petitioner is on the boards of directors of a family             
          owned telephone company, a bank holding company, and two banks.             
          Petitioner and her brother own a controlling interest in the                
          Brandenburg Telephone and First State Bank in Brandenburg,                  
          Kentucky.                                                                   
               Petitioner's friend, Brucie Beard (Ms. Beard), also lives in           
          petitioner's home.                                                          


               2 In light of our holding on the tax issues, petitioner's              
          motion for relief is moot insofar as it requests that we shift              
          the burden of proof, grant summary judgment, or suppress                    
          evidence.                                                                   





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