Suzanne F. Mottola - Page 4

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                  12. In the notice of deficiency respondent determined               
                       that petitioner was liable for an [sic] additions              
                       to tax pursuant to I.R.C. � 6651(a), in the                    
                       amount of $9,071.00 in 1992 and $9,534.00 in                   
                       1993.                                                          
                  13. Petitioner concedes her liability for the                       
                       additions to tax under I.R.C. �� [sic] 6651(a)                 
                       as determined in the notice of deficiency.                     
                  14. In the notice of deficiency respondent                          
                       determined that petitioner was liable for                      
                       an [sic] additions to tax pursuant to I.R.C.                   
                       � 6654, in the amount of $1,584.00 for the                     
                       year 1993.                                                     
                  15. Petitioner concedes her liability for the                       
                       additions to tax under I.R.C. � 6654 as                        
                       determined in the notice of deficiency.                        
                  16. Petitioner concedes that the adjustments made                   
                       in the statutory notice of deficiency are in                   
                       all respects complete and correct.                             
                  17. Petitioner is not entitled to any of the                        
                       deductions listed in her petition.                             

                  This case was calendared for trial at a prior trial                 
             session of the Court.  Petitioner appeared at the call                   
             of the prior calendar and moved for a continuance, citing                
             her own illness, her son's illness, and the fact that her                
             accountant was "about 95 percent finished" preparing her                 
             1992 and 1993 Federal income tax returns.  The Court                     
             granted petitioner's motion for continuance but pointed                  
             out to petitioner that respondent's requests for admissions              
             "are deemed to be facts under our rules and you didn't                   
             respond to them."  In response, petitioner did not advance               





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