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determined a deficiency in petitioner's Federal income tax in the
amount of $7,645.75 for the year 1989 and an addition to tax
pursuant to section 6651(a)(1) in the amount of $1,705.93. In
her answer respondent asserted that petitioner is also liable for
a penalty in the amount of $1,529.15 pursuant to section 6662(a)
because either she was negligent under section 6662(b)(1) or she
substantially understated her 1989 Federal income tax liability
under section 6662(b)(2).
Following concessions,2 the issues for decision are: (1)
Whether petitioner is entitled to deductions in the amount of
$14,312 claimed on a Schedule C, Profit or Loss from Business,
relating to her tutoring and counseling activity; (2) whether
petitioner is entitled to miscellaneous deductions in the amount
of $14,534 claimed on Schedule A, Itemized Deductions; (3)
whether petitioner is liable for the addition to tax pursuant to
section 6651(a) as determined by respondent; and (4) whether
petitioner is liable for the penalty under section 6662(a), due
to her negligence or because she substantially understated her
Federal income tax within the meaning of section 6662(d).
Some of the facts have been stipulated and are so found.
The stipulation of facts and the exhibits attached thereto are
2Respondent conceded that petitioner is not liable for self-
employment tax for the year 1989. Petitioner conceded liability
for an addition to tax pursuant to sec. 6651(a); however, she
disputes the amount as determined by respondent.
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