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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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