Joseph J. James - Page 2

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                  The issues for decision are: (1)  Whether petitioner                                 
            substantiated any rental expenses in excess of those allowed by                            
            respondent.  We find that he did to the extent stated herein.                              
            (2) Whether petitioner is entitled to deduct more than 50 percent                          
            of the expenses attributable to two rental properties he held as                           
            a cotenant, where he paid all the expenses.  We hold that he is                            
            not.2  (3) Whether petitioner is liable for additions to tax for                           
            substantial understatement of tax under section 6661.  We hold                             
            that he is to the extent stated herein.                                                    
                  In the petition, petitioner challenged the disallowance of a                         
            portion of his charitable contribution.  Petitioner did not                                
            address this issue at trial or on brief.  Thus, we find                                    
            petitioner has abandoned this claim.  Rule 151(e)(4) and (5);                              
            Petzoldt v. Commissioner, 92 T.C. 661, 683 (1989).                                         
                                         FINDINGS OF FACT                                              
                  The stipulation of facts and attached exhibits are                                   
            incorporated herein by this reference.  At the time the petition                           
            herein was filed, petitioner resided in Richmond, Virginia.                                
            Petitioner is single and filed an individual Federal income tax                            
            return for the year at issue.                                                              

                  Respondent concedes that, if the Court determines that                               
            petitioner is entitled to only 50 percent of the deductions                                
            arising from the properties held in cotenancy, petitioner should                           
            report only 50 percent of the income arising from such                                     

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