Edgar and Doris Brown - Page 2

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          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  
               After concessions,1 the issues to be decided involve the               
          substantiation of certain Schedule C business expense deductions            
          and Schedule A itemized deductions claimed by petitioners on                
          their 1991 joint Federal income tax return.2                                
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated for trial pursuant to           
          Rule 91.  The parties' stipulations of fact are incorporated                
          herein by reference and are found as facts in the instant case.             
               At the time they filed their petition in the instant case,             
          petitioners Edgar Brown (Mr. Brown) and Doris Brown (Mrs. Brown)            
          resided in Lucedale, Mississippi.  Petitioners filed a joint U.S.           
          Individual Income Tax Return (Form 1040) for the year in issue.             



          1    In the notice of deficiency, respondent determined that                
          petitioners had unreported income from Hercules, Inc., in the               
          amount of $21,429.  Subsequently, the parties conceded that                 
          petitioners have unreported income in the amount of $18,229.                
               Additionally, in the notice of deficiency, respondent                  
          disallowed certain Schedule C business expenses of petitioners.             
          Subsequently, respondent conceded that petitioners are entitled             
          to business expense deductions in the amount of $10,949 for                 
          insurance and in the amount of $543 for taxes.                              
          2    On their 1991 return, petitioners claimed exemptions in the            
          amount of $10,750 and reported self-employment taxes in the                 
          amount of $5,494.  On the basis of adjustments in the notice of             
          deficiency, respondent reduced petitioners' exemption deduction             
          by $2,580 and increased petitioners' self-employment taxes by               
          $4,753.  We sustain those computational adjustments to the extent           
          that they result from the Rule 155 computations that we order               
          below.                                                                      




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