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her returns before they were filed and clearly did not make a
reasonable effort to determine whether the returns were accurate
before authorizing her tax return preparer to file them.
Petitioner has not kept accurate records substantiating the
deductions claimed on her returns, and she and her authorized
representative testified that many of the deductions claimed on
her returns were based upon estimates or simply were made up.
Accordingly, we hold that petitioner is liable for the accuracy-
related penalties.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be
entered under Rule 155.
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Last modified: May 25, 2011