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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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Last modified: May 25, 2011