Marian Wilson - Page 18

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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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