Mary Lee Sharer - Page 16

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          her return and she would have been liable for an addition to tax                   
          for failure to file under section 6651(a) for 1986.  Similarly,                    
          if these issues had been decided in respondent's favor,                            
          petitioner then would have substantially understated her tax and                   
          would have been liable for an addition to tax under section 6661                   
          for 1986.  Finally, if these issues had been decided in                            
          respondent's favor, then petitioner's liability for additions to                   
          tax for negligence under section 6653(a) for 1986 and 1987, and                    
          for substantial understatement under section 6661 for 1987, would                  
          have been increased.                                                               
          F. Conclusion                                                                      
                As we have decided that respondent's position in both the                    
          administrative and Court proceedings for the years in issue was                    
          substantially justified, we need not decide (1) whether                            
          petitioner unreasonably protracted the proceedings, and (2)                        
          whether the administrative and litigation costs petitioner claims                  
          are reasonable.  Petitioner's motion, therefore, will be denied.                   
                                      An appropriate order and                               
                                           decision will be entered.                         














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