Susan J. Bokhari O'Neil - Page 2

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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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