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alien and is not subject to the Federal income tax. Following a
hearing on the matter, we granted respondent's motions for
partial summary judgment. Fox v. Commissioner, T.C. Memo. 1993-
37.
As previously indicated, these cases are now before the
Court on the parties' cross-motions for summary judgment.
Respondent seeks judgments in her favor with respect to all
remaining issues.4 The issues remaining in dispute are: (1)
Whether petitioner failed to report interest and dividend income
on his 1983, 1984, and 1985 tax returns; (2) whether petitioner
is entitled to a loss of $3,880 reported on Schedule C attached
to his 1983 tax return; (3) whether petitioner is entitled to a
loss in the amount of $2,410 claimed on his 1986 tax return; (4)
whether petitioner is liable for additions to tax pursuant to
section 6661 (substantial understatement of liability) for the
taxable years 1983 through 1987; and (5) whether petitioner is
4 For the sake of completeness, we note that by order dated
Dec. 6, 1995, we granted respondent's motion to dismiss for lack
of jurisdiction and to strike with respect to the sec. 6654
addition to tax, filed in docket No. 16560-90. In addition,
respondent conceded (by way of stipulation) that petitioner is
entitled to the full amount of losses reported on his returns
with respect to his investment in Coram Taxvest Windfarms for the
taxable years 1985, 1986, and 1987. Respondent also conceded
that petitioner is not liable for any additions to tax with
respect to his investment in Coram Taxvest Windfarms for the
taxable years 1985, 1986, and 1987, or for the addition to tax
under sec. 6653(a) for the taxable year 1982. Although not
mentioned in the stipulations regarding petitioner's investment
in Coram Taxvest Windfarms, respondent likewise concedes that
petitioner is not liable for increased interest pursuant to
section 6621(c) for the taxable years 1982, 1985, and 1986.
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