Kenneth Lee Anderson and Carol Jane - Page 12




                                       - 12 -                                         

               It would serve no useful purpose to recount the deemed                 
          admitted facts at length; they are set forth supra pp. 4-6.  It             
          suffices to say that they cover all matters set forth in the                
          statutory notice of deficiency that were not disposed of by the             
          Court's prior opinion in this case.  We therefore hold that, as a           
          result of the foreclosure of the Calmin Drive property,                     
          petitioner Kenneth Anderson had cancellation of indebtedness                
          income of $275,000 in 1992.  In the absence of the furnishing by            
          petitioners of any information regarding their basis in the                 
          Calmin Drive property, the gain determined by respondent on the             
          disposition of the property in 1992 is sustained.  In the absence           
          of presentation by petitioners of any information or                        
          documentation that they are entitled to deductions for the years            
          1992-95 inclusive, petitioners are not entitled to any deductions           
          in computing their adjusted gross income or taxable income for              
          those years.  Petitioner Kenneth Anderson received unemployment             
          compensation of $3,480 in 1992, and he is subject to self-                  
          employment taxes for 1992 and 1993.  Finally, petitioners are               
          liable for the accuracy-related penalty under section 6662(a) for           
          each of the years 1992 through 1995.                                        
          Issue 2.  Section 6673 Penalty                                              
               The Court, in its prior opinion in this case, decided to               
          impose a penalty of $10,000 under section 6673 on the grounds of            







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