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Respondent determined a $989 penalty for 2001 and a $947
penalty for 2002. We sustain the penalty for each year.
Petitioner’s records are wholly inadequate to substantiate the
disallowed deductions. Petitioner’s failure to maintain records
is especially egregious considering that she worked for the
Internal Revenue Service during the years at issue. Petitioner
should understand the record-keeping requirements imposed by the
Internal Revenue Code. See sec. 6001. Petitioner should also
understand why the evidence she introduced at trial fails to
satisfy those requirements. Respondent’s determination is
sustained.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: November 10, 2007