Julie Pusateri - Page 8

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               The gross receipts for the Schedule C-2 business were                  
          $3,692.  When we deduct the expenses stipulated as substantiated            
          by petitioner of $7,859, petitioner had a net loss of $4,167 for            
          her Schedule C-2 paralegal business.  This again is in sharp                
          contrast to the $11,572 loss petitioner reported on the original            
          Schedule C-2.                                                               
               Petitioner made no argument with respect to the denial of              
          the $96 child care credit and we deem this issue conceded.                  
               Respondent determined that petitioner is liable for an                 
          accuracy-related penalty under section 6662(a) for 1991.  Section           
          6662(a) and (b)(1) imposes a penalty on any portion of an                   
          underpayment that is attributable to negligence or disregard of             
          rules or regulations.  The term "negligence" includes any failure           
          to make a reasonable attempt to comply with the statute, and the            
          term "disregard" includes any careless, reckless, or intentional            
          disregard.  Sec. 6662(c).  The penalty does not apply to any                
          portion of an underpayment for which there was reasonable cause             
          and with respect to which the taxpayer acted in good faith.  Sec.           
          6664(c).  Respondent's determinations are presumed correct, and             
          petitioner bears the burden to prove she is not liable for the              
          accuracy-related penalty under section 6662(a).  Rule 142(a);               
          Neely v. Commissioner, 85 T.C. 934, 947 (1985); Bixby v.                    
          Commissioner, 58 T.C. 757, 791-792 (1972).                                  

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