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section 6651(a)1 of $1,476.75, and an addition to tax under
section 6654(a) of $206.50.
After concessions,2 we must decide the following issues:
(1) Whether petitioner is entitled to certain business
expense deductions. We hold that she is, to the extent discussed
below.
(2) Whether petitioner is entitled to a charitable
contribution deduction. We hold that she is, to the extent
discussed below.
(3) Whether petitioner is entitled to a casualty loss
deduction. We hold that she is not.
(4) Whether petitioner is entitled to a bad debt deduction.
We hold that she is not.
(5) Whether petitioner is liable for an addition to tax
under section 6654(a). We hold that she is, to the extent
discussed below.
1 Unless otherwise noted, 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.
2 Petitioner has conceded that she is liable for the
addition to tax under sec. 6651(a).
Petitioner did not file a return for 1993 prior to
respondent’s issuance of the notice of deficiency. In her 1993
return subsequently submitted, petitioner claimed a deduction
with respect to an individual retirement account. The parties
have not addressed this issue, and we accordingly treat the
deduction as conceded by petitioner.
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