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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has shown no reason why we should allow them to be withdrawn.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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