Sharon T. Myrick - Page 8




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          failure by a taxpayer to keep adequate books and records or to              
          substantiate items properly.  Sec. 1.6662-3(b), Income Tax Regs.            
               An accuracy-related penalty is not imposed with respect to             
          any portion of the underpayment as to which the taxpayer acted              
          with reasonable cause and in good faith.  Sec. 6664(c)(1); see              
          Higbee v. Commissioner, supra at 448.  This determination is                
          based on all the relevant facts and circumstances.  Higbee v.               
          Commissioner, supra at 448; sec. 1.6664-4(b)(1), Income Tax Regs.           
          “Relevant factors include the taxpayer’s efforts to assess his              
          proper tax liability, including the taxpayer’s reasonable and               
          good faith reliance on the advice of a professional such as an              
          accountant.”  Higbee v. Commissioner, supra at 448-449.                     
               Petitioner has failed to keep or produce adequate records.             
          Respondent has provided sufficient evidence to meet his burden of           
          production.  Although petitioner had a background in tax law, she           
          failed to show that she kept proper records to establish her                
          entitlement to her claimed deductions.  Petitioner has failed to            
          show she acted with reasonable care or in good faith and has not            
          produced reliable evidence to prove that respondent’s                       
          determination of negligence is incorrect.  We hold that                     













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