Federal Tax Research 10th Edition by Steven Gill, Gerald Whittenburg, Roby Sawyers, Debra Sanders, William Raabe

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Joan, a traveling sales representative, kept no formal books and records to summarize her gross receipts forthe year, but she retained copies of all customer invoices and reported her gross income for the year from these totals. Is she liable for a negligence penalty under I.R.C. § 6662 for failing to keep any books and records