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2000 and 2001, the deficiencies exceed $5,000. For 2002,
respondent asserts that the underpayment of tax is attributable
to negligence, because petitioner failed to maintain adequate
books and records to substantiate the deductions claimed. There
is no question in this case that the records were inadequate.
Petitioner relied upon her husband to prepare her returns and
keep her records. Unfortunately, his efforts in this regard were
inadequate, and there is insufficient evidence of reasonable
cause for petitioner’s failure to maintain proper records.
Accordingly, we find the penalty under section 6662(a) is
applicable to the deficiencies for the years in question.
To reflect the foregoing and concessions by respondent,
Decision will be entered
under Rule 155.
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Last modified: November 10, 2007