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her proper tax liability. See Tippin v. Commissioner, 104 T.C.
518, 533-34 (1995); sec. 1.6664-4(b)(1), Income Tax Regs.
Petitioner contends that she based the information contained
in her Federal income tax returns for the years in issue on
information provided by Special Occasions and Special O and that
she therefore made a good faith effort to comply with the
provisions of the Code. We disagree.
Petitioner possessed tax expertise because of her profession
and knowledge of the financial condition of Special Occasions and
Special O. Petitioner wrote most of the checks drawn on the
single bank account maintained by both Special Occasions and
Special O. Furthermore, petitioner failed to maintain adequate
books and records from which her claims to deductions and losses
could be determined or substantiated.
We find that petitioner is liable for an accuracy-related
penalty pursuant to section 6662(a) for the 1991, 1992, and 1993
tax years. Respondent is sustained on this issue.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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