Veronica L. Foster - Page 3




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          reviewable by any other court, and this opinion shall not be                 
          treated as precedent for any other case.  Unless otherwise                   
          indicated, subsequent section references are to the Internal                 
          Revenue Code (Code) in 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 $1,436 in petitioner’s            
          2002 Federal income tax and an accuracy-related penalty under                
          section 6662 of $287.20.                                                     
               The issues for decision are:  (1) Whether petitioner is                 
          entitled to deduct the expenses of her master of business                    
          administration (M.B.A.) program at Harvard Business School (HBS);            
          and (2) whether petitioner is liable for the section 6662 penalty            
          for negligence or disregard of rules or regulations.                         
                                      Background                                       
               The parties stipulated some of the facts, and they are so               
          found.  We incorporate the stipulation of facts and the attached             
          exhibits herein by this reference.  Petitioner resided in                    
          California when she filed the petition in this case.2                        




               2 The Court conducted the trial of this case in Boston,                 
          Mass., as petitioner requested.  Petitioner did not attend the               
          trial.  Presumably, she still lived in California at the time of             
          trial.  As will be discussed infra, petitioner did not provide               
          any testimony at trial.  The record is thus limited to the                   
          stipulation of facts with attached exhibits, matters deemed                  
          admitted, Rule 90(c), and additional exhibits admitted in                    
          evidence at trial.                                                           





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