Ajuba Gaylord - Page 16

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          made by taking into account all the pertinent facts and                     
          circumstances.  See sec. 1.6664-4(b)(1), Income Tax Regs.                   
               In her Federal tax returns, petitioner claimed excessive               
          Schedule C and Schedule A expenses that she was unable to                   
          substantiate, thereby disregarding the requirements of sections             
          162 and 274.  Further, neither the receipts petitioner submitted            
          nor her testimony establish a business purpose for the claimed              
          expenses.                                                                   
               At trial petitioner failed to demonstrate that she acted in            
          good faith with respect to the underpayments during the years at            
          issue.  Accordingly, we hold that petitioner is liable for                  
          accuracy-related penalties under section 6662(a) for 1999 and               
          2000.                                                                       
               To reflect the foregoing,                                              

                                                  Decisions will be entered           
                                             under Rule 155.                          




















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