HUTCHESON, Chief Judge.
This appeal is by the taxpayer from a decision of the Tax Court, sustaining the commissioner's determination as to deficiencies and penalties. Her counsel concedes that the taxpayer, who conducted her own defense poorly and ineffectively, failed to carry her burden of proof as to the taxes in the original ninety day letter, and the decision should be affirmed as to those deficiencies. He, however, insists that the commissioner has not borne...
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