Evelyn J. Glenn - Page 21




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           itself, a basis for sustaining the accuracy-related penalty.               
           In this regard, we observe that a taxpayer is required to                  
           maintain records sufficient to establish all items of income,              
           deduction, and credit that are required to be shown on the                 
           taxpayer’s tax return.  See sec. 6001; sec. 1.6001-1(a), Income            
           Tax Regs.; see also Lysek v. Commissioner, 583 F.2d 1088, 1094             
           (9th Cir. 1978), affg. T.C. Memo. 1975-293; Crocker v.                     
           Commissioner, 92 T.C. 899, 916 (1989); Schroeder v.                        
           Commissioner, 40 T.C. 30, 34 (1963); sec. 1.6662-3(b)(1),                  
           Income Tax Regs.  Additionally, failure to keep adequate                   
           records is evidence of intentional disregard of the                        
           regulations.  See Crocker v. Commissioner, supra at 917.                   
                In the present case, petitioner failed to report over                 
           $29,000 of gross income from her proprietorship in 1995.                   
           Moreover, for both 1995 and 1996, petitioner claimed NOL                   
           deductions and various Schedule C deductions for which she did             
           not maintain substantiation required by law.                               
                Based on the foregoing, and insofar as 1996 is concerned,             
           respondent has satisfied his burden of production under section            
           7491(c).  Insofar as 1995 and 1996 are concerned, petitioner               
           has failed to establish that she acted reasonably with respect             
           to the underpayment of her taxes for those years.  We therefore            
           sustain respondent’s determination and hold that petitioner is             
           liable for the accuracy-related penalties for 1995 and 1996.               






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