Timothy A. Runels and Emma Valdivieso Runels, et al. - Page 3




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          treated as precedent for any other case.  Unless otherwise                  
          indicated, subsequent section references are to the Internal                
          Revenue Code in effect for the years in issue, and all Rule                 
          references are to the Tax Court Rules of Practice and Procedure.            
               Respondent determined deficiencies of $6,391, $4,838 and               
          $3,479 in petitioners’ 2002, 2003, and 2004 Federal income tax,             
          respectively.  Respondent also determined that petitioners are              
          liable for accuracy-related penalties under section 6662(a) of              
          $1,278.20 for 2002, $967.60 for 2003, and $18 for 2004.                     
               Respondent concedes that the adjustment to petitioners’                
          gross receipts for 2002 reported on Schedule C, Profit or Loss              
          From Business, should be $11,169.  Respondent also concedes that            
          for 2003, the Schedule C depreciation adjustment should be                  
          $8,504; and for 2004 the Schedule C adjustments should be $5,843            
          for “other expenses” and $995 for depreciation, the self-                   
          employment tax is $303, and the self-employment tax deduction is            
          $152.                                                                       
               Petitioners concede as correct the adjustment for rent/lease           
          of business property for 2002 and the adjustments to Schedule F,            
          Profit or Loss From Farming, for 2002 and 2003.  Petitioners                
          presented no evidence or argument with respect to respondent’s              
          adjustments to itemized deductions for 2002, 2003, and 2004.  The           
          Court therefore deems the latter adjustments to have been                   
          conceded by petitioners.  See Rule 149(b); Rothstein v.                     







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