Sheriel L. Sexcius - Page 2

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          section 6662(c) or for substantial understatement under section             
          6662(d).  Unless otherwise indicated, all section references are            
          to the Internal Revenue Code in effect for the year in issue, and           
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  
               At the beginning of trial, petitioner, by her then counsel,            
          conceded that petitioner was not entitled to any deductions from            
          her tutoring activity in excess of the income reported.  In her             
          opening brief, petitioner conceded that her return was filed late           
          and offered no explanation; she thus conceded liability for the             
          addition to tax under section 6651(a).  Although petitioner                 
          attempted to repudiate these concessions in her reply brief, she            
          has shown no reason why we should allow them to be withdrawn.               
          The remaining issues are whether petitioner is entitled to a                
          dependency exemption for her mother, to deductions claimed in               
          relation to her tutoring activity, or to miscellaneous deductions           
          claimed on Schedule A of her Federal income tax return; whether             
          petitioner is liable for a penalty under section 6662(a); and               
          whether we should impose a penalty under section 6673.                      
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.  At the           
          time that she filed her petition, petitioner resided in                     
          Washington, D.C.                                                            





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