Taxpayer was notified of a limited scope audit (C-SPAN) based on a discrepancy between the business income reported on her 1994 federal income tax return and the receipts reported to New Mexico. Taxpayer was notified that she had a 60-day period to provide evidence (NTTCs) to support her deductions. Taxpayer failed to provide the NTTCs before the 60-day period expired. Taxpayer relied on the erroneous advice of her accountant that she did not need to obtain the NTTCs. The taxpayer was not negligent. Taxpayer’s protest is granted as to the assessment of penalty. The protest is denied for all other issues.
Eileen P. Cahoon