Daniel R. Leavell and Eva Lovene Leavell - Page 2

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                                 Additions to Tax                                                         
                                              Sec.            Sec.                                        
                                 Sec.         6653(a)(1)/      6653(a)(2)/       Sec.                     
            Year   Deficiency    6651(a)(1)   6653(a)(1)(A)    6653(a)(1)(B)     6661(a)                  
            1985   $352,825      $88,206         $17,641              *          $ 88,206                 
            1986   85,404          21,351        4,270                *          21,351                   
            1987   526,354        __             26,318               *          131,589                  

                            *  50 percent of interest due on portion of                                   
                            underpayment attributable to negligence.                                      

                   Unless otherwise indicated, all section references are to                              
            the Internal Revenue Code in effect for the years in issue, and                               
            all Rule references are to the Tax Court Rules of Practice and                                
            Procedure.                                                                                    
                   After concession of some issues by each party, the primary                             
            issues remaining for decision are:  (1) The amount, if any, of                                
            net operating loss, investment interest, and investment credit                                
            carryovers from 1984 to which petitioners are entitled for the                                
            years in dispute; (2) whether a residence sold by petitioners in                              
            1986 was used by petitioners as a personal residence; (3) the                                 
            amount of gain petitioners realized in 1985, 1986, and 1987 in                                
            connection with two transactions relating to the sale of stock;                               
            (4) whether petitioners have substantiated claimed operating                                  
            expenses and costs-of-goods sold with regard to various                                       
            businesses; (5) whether Eva Leavell has substantiated for 1986 a                              
            claimed net operating loss of $20,378 relating to oil production;                             
            and (6) whether petitioners are liable for the additions to tax.                              







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