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Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the years in issue, and Rule
references are to the Tax Court Rules of Practice and Procedure.
On April 30, 1992, Eva F. Berglund died in Danville,
Illinois. On May 16, 1994, respondent filed a motion to dismiss
for lack of prosecution as to Eva F. Berglund. On July 25, 1994,
we granted respondent's motion to dismiss. References to
petitioner are to Evert E. Berglund. Amounts determined to be
due from petitioner will also be determined to be due from Eva F.
Berglund. References to petitioner's spouse are to Eva F.
Berglund.
After concessions by respondent,1 the remaining issues for
decision are: (1) Whether petitioner had taxable capital gain in
1986 from the sale of approximately 652 acres of farmland; (2)
whether petitioner's spouse had taxable pension income of
1Respondent has conceded that petitioner is not liable for
the additions to tax for the year 1986 pursuant to the provision
of secs. 6661 and 6653(a)(1)(A) and (B). Respondent has
conditionally conceded that petitioner is entitled to various
unclaimed deductions during the years in issue. Respondent's
conditional concessions are contingent upon this Court's finding
that petitioner sold approximately 652 acres of farmland in 1986.
Respondent has conditionally conceded that petitioner is entitled
to previously unclaimed interest expense deductions for the years
1986, 1987, and 1988 in the amounts of $147,624.52, $11,987.85,
and $3,774.01, respectively. Respondent has also conditionally
conceded that petitioner is entitled to use previously unclaimed
net operating loss deductions in the years 1986, 1987, and 1988
in the amounts of $64,196, $12,736, and $13,786, respectively.
Based on respondent's concessions and conditional concessions,
petitioner's income tax liabilities for the years 1986, 1987, and
1988 are $0, $0, and $784, respectively.
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