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effect for the year in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
Respondent determined a deficiency of $28,449 in
petitioner's Federal income tax for the year 1996, and an
addition to tax under section 6651(a)(1) of $5,805.04.
We must decide: (1) Whether petitioner is entitled to
deduct Schedule C expenses in amounts greater than respondent has
determined; (2) whether petitioner has additional self-employment
income; and (3) whether petitioner is liable for an addition to
tax under section 6651(a)(1).
Petitioner failed to substantiate her deductions on audit.
She failed to stipulate matters with respondent before trial. At
trial, she refused to stipulate matters which she said were
correct. The Court took a long recess for stipulation purposes.
Although respondent was willing to concede a number of items in
petitioner’s favor, she still refused to stipulate. Finally,
only after the intervention of the Court, did petitioner
stipulate in part.
To the limited extent stipulated, the facts are so found.
Petitioner resided in Sylmar, California, at the time her
petition was filed.
Petitioner reported $9,240 as other income from services as
a notary public. On her Schedule C, Profit or Loss From
Business, for “Morin Business Services” (MBS), petitioner
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