FINDINGS OF FACT AND OPINION
HALPERN, Judge.
By notice of deficiency dated November 4, 2003 (the Notice), respondent determined deficiencies in petitioner's Federal income tax liabilities of $2,114 and $2,499 for her taxable (calendar) years 2000 and 2001 (the audit years), respectively, and accuracy-related penalties of $422.80 and $499.80 for 2000 and 2001, respectively. At the trial of this case, petitioner conceded respondent's denial, for lack of substantiation...
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