- 2 - 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attempted to repudiate these concessions in her reply brief, she has shown no reason why we should allow them to be withdrawn.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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011