Martin H. Droz - Page 2

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          related penalty under section 6662(a) in the amounts of $15,672             
          and $11,967, respectively.                                                  
               The issues remaining for decision are:                                 
               (1) Is petitioner entitled for 1991 to a charitable con-               
          tribution deduction under section 170(a) for a flight helmet that           
          he donated to a museum during that year?  We hold that he is                
          entitled to a deduction in the amount of $500.                              
               (2) Is petitioner liable for 1991 for self-employment tax?             
          We hold that he is.                                                         
               (3) Is petitioner liable for 1991 for the accuracy-related             
          penalty under section 6662(a)?  We hold that he is.                         
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
               Petitioner had a mailing address in Arcadia, California, at            
          the time the petition was filed.                                            
               At all relevant times, petitioner operated a sole proprie-             
          torship that engaged in the business of distributing plumbing               
          products.                                                                   
               In June 1977, in response to a newspaper advertisement by an           
          individual in Downey, California, petitioner purchased for $100             
          a high-altitude, full-pressure flight helmet made in 1959 that              
          was used by the U.S. Navy and that is known, and hereinafter                
          referred to, as a Mark IV helmet.                                           
               A Mark IV helmet is not a space helmet and was not at any              





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