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addition to tax under section 6653(a) for 1988 in the amount of
$50, and an accuracy-related penalty under section 6662 with
respect to 1989 in the amount of $278.
The issues are: (1) Whether this Court is unconstitutional
and lacks jurisdiction over petitioner's tax deficiencies; (2)
whether petitioner was engaged in the trade or business of being
a broker during the years at issue, and, if so, whether
petitioner is entitled to various deductions as claimed on his
Schedules C for those years; (3) whether petitioner is liable for
an addition to tax pursuant to section 6653(a) for 1988; and (4)
whether petitioner is liable for an accuracy-related penalty with
respect to 1989 pursuant to section 6662.
Some of the facts have been stipulated and are so found.
The stipulation of facts and exhibits received into evidence are
incorporated by this reference. Petitioner resided in Inverness,
Florida, at the time his petition was filed in this case.
In or around 1979, petitioner resided in Indianapolis,
Indiana, and worked as a business broker and consultant. He
formed K.R. Bradbury & Associates, Inc. (KRBA) in or about 1980,
a corporation engaged in selling businesses and in management
consulting. In 1982, petitioner sold one-third of KRBA to Ray
Leonard, a licensed real estate agent, and changed the corporate
name to Bradbury, Leonard & Associates, Inc. (BLA). Shortly
thereafter, petitioner sold his remaining interest in BLA to a
third party and formed Executive Computer Corp. (ECC), a
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