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and adopts the Special Trial Judge's opinion, which is set forth
below.
OPINION OF THE SPECIAL TRIAL JUDGE
DEAN, Special Trial Judge: Respondent determined a
deficiency in petitioner's 1991 Federal income tax in the amount
of $10,610 and an accuracy-related penalty under section 6662(a)
in the amount of $2,122.2
After concessions,3 the issues for decision are: (1)
Whether petitioner has substantiated various itemized deductions
claimed on Schedule A of her 1991 Federal income tax return; and
(2) whether petitioner is liable for an accuracy-related penalty
under section 6662(a) for negligence or disregard of rules or
regulations.
2Petitioner originally elected to have her case heard as a
small tax case under Rule 172 and sec. 7463. However, in
reviewing the record, we have determined that the sum of the
deficiency disputed by petitioner and the penalty stipulated as
an issue in this case ($2,122) is in excess of the $10,000
statutory limit for small tax cases. Rule 171(a); sec. 7463(a).
The "S" designation of this case was therefore removed pursuant
to our own motion. Rule 173; sec. 7463(d).
3For the year at issue, for which petitioner and her husband
filed a joint income tax return, petitioner has conceded that
she: (1) Is not entitled to Schedule C deductions in the amount
of $13,125 claimed with respect to her husband's export-import
business, and (2) failed to report taxable interest income in the
amount of $190. Respondent has conceded that petitioner is
entitled to Schedule C deductions in the amount of $17,575 with
respect to her husband's taxi cab business. To the extent
indicated below, respondent has also made concessions with
respect to certain deductions claimed on petitioner's Schedule A.
Finally, respondent acknowledges that, to the extent petitioner
is liable for self-employment tax under sec. 1401, she will be
allowed a corresponding deduction under sec. 164(f).
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