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Washington, 459 F. Supp. 1020, 1095 (W.D. Wash. 1978). There is
no evidence to support petitioner’s contention. Petitioner did
not testify that the photo shop charged expenses on her credit
cards, and her claim after trial that the photo shop charged its
expenses on her credit cards is reason to disbelieve her trial
testimony.
Another reason for disbelieving petitioner’s trial testimony
is the fact that she said in her answering brief that we should
disregard her trial testimony relating to her photo store salary.
It is not clear what parts of petitioner’s testimony we should
believe under these circumstances.
Petitioner contends that some of the money that she
deposited was her own money that she had withdrawn for gambling
and redeposited afterwards. Petitioner’s testimony in this
regard was very general. She provided us no basis to decide
which of the bank deposits were redeposits of money she had
withdrawn.
We conclude that, in addition to the $13,000 salary that
petitioner earned each year from the photo store, petitioner had
unreported income of $25,500 for 1993 and $5,486 for 1994.
C. Whether Petitioner Is Liable for the Addition to Tax for
Failure To File Her 1993 Income Tax Return
Respondent determined that petitioner is liable for the
addition to tax under section 6651(a) for failure to file a
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