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year. On December 20, 1994, respondent had issued petitioners
separate notices of deficiency reflecting her determination that
they were liable for the following deficiencies in Federal income
tax and additions thereto:
Simpson Financial Services, Inc., docket No. 4255-95
Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6653(a)(1) 6661
1988 $28,225 $7,056 $1,411 $7,056
Richard H. and Christine R. Simpson, docket No. 4354-95
Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6653(a)(1) 6661
1988 $13,083 $3,271 $778 $3,271
Prior to trial, the parties settled all issues raised in
respondent's notices of deficiency. In their settlement
agreement, the parties agreed that there remained a deficiency
for Simpson Financial Services, Inc., for its 1988 taxable year
in the amount of $1,579, and a $395 addition thereto under
section 6651(a)(1). Respondent conceded all adjustments with
respect to Richard H. and Christine R. Simpson.
Following this agreement and concession, we must decide
whether respondent's position was substantially justified in fact
and law for purposes of section 7430(c)(4)(A)(i).1 We conclude
1 Respondent filed her answers on Apr. 20, 1995, generally
denying all material allegations of error contained in the
petitions. Respondent's position taken in her answers was the
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