- 2 -
Respondent determined deficiencies in, and an addition to,
petitioners’ Federal income taxes for the taxable years 1996 and
1997 as follows:
Addition to tax
Year Deficiency Sec. 6651(a)(1)
1996 $10,385 $200
1997 6,878 ---
After petitioners’ concessions,2 the issue for decision is
whether petitioner Richard B. May (petitioner) elected under
section 469(c)(7)(A) to treat his various rental real estate
activities as a single activity for the years in issue. We hold
that he did not.
An adjustment to the amount of petitioners’ itemized
deductions for each of the years in issue is a purely
computational matter, the resolution of which is dependent on our
disposition of the disputed issue.
Background
Some of the facts have been stipulated, and they are so
found. We incorporate by reference the parties’ stipulation of
facts, supplemental stipulation of facts, and accompanying
exhibits.
2 Petitioners concede: (1) They are not entitled to claim
the dependency exemption deductions disallowed by respondent in
the notice of deficiency, and (2) they are liable for the
addition to tax for failure to timely file their Federal income
tax return for 1996.
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