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At the beginning of trial in this case, faced with
respondent's request for another penalty under section 6673,
petitioner's then counsel conceded that petitioner was not
entitled to deductions in excess of the income received from the
tutoring and counseling activity and indicated that petitioner's
intention was to substantiate deductions up to the amount of that
income. Notwithstanding the experience of six prior cases in the
Court, petitioner failed to present adequate records. The
documents that were presented established that petitioner was
claiming deductions for some personal expenses and failed to
establish the business purpose of other expenditures.
Similarly, with respect to her claim that she is entitled to
a dependency exemption for her mother, petitioner's proof is
totally inadequate. She could not provide the amount of her
mother's earnings for 1990 and did not know whether her mother
had filed a Federal income tax return for that year claiming an
exemption for herself. Petitioner's only evidence with respect
to this issue consisted of receipts for expenditures for the
house that she shared with her mother. There was some indication
that some of these expenses were paid by her mother. Thus,
petitioner has not satisfied the requirements of section
151(c)(1), relating to earnings of a dependent, or section
151(d)(2), relating to dependents for whom exemptions are claimed
on returns filed by another taxpayer. We cannot conclude on this
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