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III. Conclusion
We have analyzed all of the testimony, exhibits, and
stipulations in this unwieldy record in an effort to fairly and
justly decide the issues presented by this case. The task has
not been easy due largely to respondent’s failure to examine
petitioner’s documentation before issuing the notices of
deficiency in this case and respondent’s blanket disallowance of
all of petitioner’s Schedule C expenses for 3 of the 4 years at
issue. As petitioner conceded more than once at trial, however,
petitioner must also take some responsibility for the gaps in the
record presented to this Court. By failing to maintain formal
books of account to summarize and organize her voluminous
documentation, petitioner left herself exposed to the problems
presented by this case and must accept a less than perfect
result.
We have considered all of the arguments expressly or
inferentially raised in this case by either party, and, to the
extent not discussed, we find them to be irrelevant or without
merit.
In light of the foregoing and to reflect concessions made by
the parties,
Decisions will be entered
under Rule 155.
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