Evelyn M. Martin - Page 19




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          that petitioner is not liable for the addition to tax for                   
          negligence for either taxable year.                                         
               With respect to the delinquency addition, petitioner has               
          failed to offer evidence that would relieve her of that                     
          obligation, and, to the extent that the Rule 155 computation                
          results in any income tax deficiency due from petitioner, she               
          will be liable for the section 6651(a)(1) delinquency addition to           
          tax.                                                                        
               To account for concessions of the parties and to reflect the           
          foregoing,                                                                  
                                             Decision will be entered                 
                                        under Rule 155.                               



























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Last modified: May 25, 2011