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in the amount of $6,339 and an accuracy-related penalty under
section 6662(a) in the amount of $1,268.
After concessions by the parties, the issues for decision
are: (1) Whether petitioners are entitled to an itemized
deduction for moving expenses; (2) whether John K. Jorman was
engaged in a trade or business related to the real estate
industry during the year 1991 so as to allow for deductions under
section 162(a); and (3) whether petitioners negligently filed
their 1991 Federal income tax return so as to render them liable
for the accuracy-related penalty imposed by section 6662(a).
Some of the facts have been stipulated and are so found.
The stipulation of facts and the exhibits attached thereto are
incorporated herein by this reference. During the year in issue,
petitioners were husband and wife and filed a joint Federal
income tax return. At the time that the petition was filed,
John K. Jorman resided in Plainfield, Indiana, and Audrey Jorman
resided in Indianapolis, Indiana. References to petitioner are
to John K. Jorman.
FINDINGS OF FACT
During the year in issue, petitioner was employed as a
customer service supervisor with PSI Energy, Inc. (PSI).
Petitioner began his employment with PSI on March 30, 1990, in
Bloomington, Indiana. When he started with PSI he was living in
Indianapolis, Indiana. He moved to an apartment in Bloomington
sometime in May or June of 1990. Toward the end of 1990,
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