Michael J. Downing and Sandra M. Downing - Page 6

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          are as follows:                                                             
                    (1)  Whether each petitioner omitted from gross income            
               his or her respective community property law one-half                  
               interest in the spouse’s earnings.                                     
                    (2) Whether petitioners had unreported Schedule C gross           
               receipts for the years in issue, and, if so, then in what              
               amounts.                                                               
                    (3)(a) Whether petitioners are liable for the civil               
               fraud additions to tax under section 6663, or (b) in the               
               alternative, if petitioners’ underpayments (if any) are not            
               due to fraud, then whether petitioners are liable for the              
               negligence additions to tax under section 6662(a).                     





               2(...continued)                                                        
          shows gross receipts of $82,721--petitioners acknowledge 1995               
          plumbing business gross receipts of $88,502.                                
               On brief, respondent indicates that respondent’s concessions           
          have the effect of reducing the original deficiency notice                  
          determination by more than one-third as to Michael and by more              
          than half as to Sandra.  Further concessions were made in the               
          course of certain postbrief proceedings.  Infra note 24.                    
          Computations will be required under Rule 155.                               
               Unless indicated otherwise, all Rule references are to the             
          Tax Court Rules of Practice and Procedure.                                  
               3  The following adjustments are computational: (1) The                
          deduction for exemptions, (2) the child care credit, and (3) the            
          computation of both Michael’s self-employment tax liability and             
          self-employment tax deduction; their resolution depends on our              
          determination of the issues for decision.                                   




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