- 16 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16
Last modified: May 25, 2011