Karen Boyd - Page 10




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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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