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1. Whether petitioners understated their taxable interest
income by $11,801. We hold they did.
2. Whether petitioners overstated their deductible rental
loss by $48,129. We hold they did.
3. Whether, without consideration of the interest income
and the rental loss mentioned above, petitioners understated
their gross income by $17,014. We hold they did not.
4. Whether petitioners are liable for the addition to tax
and accuracy-related penalty determined by respondent under
sections 6651(a)(1) and 6662(a), respectively. We hold they are.
Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the year in issue. Rule
references are to the Tax Court Rules of Practice and Procedure.
Dollar amounts are rounded to the nearest dollar.
FINDINGS OF FACT1
Some of the facts have been stipulated and are so found.
The stipulations of fact and the exhibits submitted therewith are
incorporated herein by this reference. Petitioners are husband
and wife. They resided in Soldotna, Alaska, when they petitioned
the Court. They were experiencing financial difficulties during
1 We have given no consideration to documents that
petitioners attached to their brief. These documents are not
evidence. Rule 143(b); West 80th St. Garage Co. v. Commissioner,
12 B.T.A. 798, 800 (1928); Boyd Gaming Corp. v. Commissioner,
T.C. Memo. 1997-445; see also Saunders v. Commissioner, T.C.
Memo. 1992-361, and the cases cited therein.
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