Ragnhild A. Westby - Page 88

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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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