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suspect in view of her total concessions with regard to the
disallowance of travel and meals and entertainment expenses of
$2,620, other deductions of $4,000, and repair/maintenance
deductions of $1,200. We find that respondent has met his burden
of production under section 7491(c) through petitioner’s above
concessions, along with evidence in the record indicating that
petitioner lacked proper record keeping for the accurate
preparation of her 1997 return. Higbee v. Commissioner, 116 T.C.
438, 449 (2001). Accordingly, petitioner is liable for the
negligence penalty under section 6662(a)(1).
We have considered all arguments by the parties, and, to the
extent not discussed above, conclude that they are irrelevant or
without merit.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011