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See Wichita Terminal Elevator Co. v. Commissioner, 6 T.C. 1158,
1165 (1946), affd. 162 F.2d 513 (10th Cir. 1947).
Petitioner has not presented any substantiation of
deductions claimed on the Forms 1120S or any other deductions
that she wished to claim on her Forms 1040. In effect, she has
received the benefit of some unsubstantiated deductions from the
gross income acknowledged on the Forms 1120S, which exceeds the
income determined to be taxable to her. We cannot conclude that
the income set forth in the statutory notices as compensation for
her medical services exceeds the correct total income taxable to
her as wages or as S corporation income. She has not identified
any error in the determinations of interest or capital gain
income. She has given us no indication that personal itemized
deductions exceed the standard deduction allowed in the statutory
notices.
The record contains copies of the Forms 1040 submitted by
petitioner for 2000 and 2002. For 2000, respondent determined a
penalty under section 6662(a). Petitioner’s Form 1040, with its
frivolous attachment, on its face establishes negligence.
Petitioner’s testimony that an unidentified accountant advised
her that she could file “zero income returns” does not show
reasonable reliance or good faith and is not credible.
For 2001, respondent contends, and petitioner does not deny,
that petitioner did not file a return. For 2002, the record
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