2
Penalty
Year Deficiency Sec. 6662
1990 $1,859 $372
1991 6,891 1,378
1992 1,157 231
All statutory 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, except as
otherwise noted.
By stipulation of the parties, this case was submitted under
Rule 122. By further stipulation, petitioners have conceded the
deficiencies in tax that were determined by respondent for the
years 1991 and 1992. As to the year 1990, petitioners have
conceded all respondent's adjustments to income except
respondent's determination that petitioners' receipt of $43,469
of income in that year constituted income subject to self-
employment tax, rather than rental income as claimed by
petitioners. As to the penalties, petitioners have explicitly
not conceded the determined penalties for the years 1991 and
1992; the determined penalties for the year 1990 are not
mentioned in the parties' stipulation of settled issues, and we
therefore consider this item still to be in dispute.
Petitioners Connie D. Ray and Roma Kay Ray, husband and
wife, filed joint income tax returns for the years 1989, 1990,
1991, and 1992. At the time the petition herein was filed,
petitioners were residents of Texas.
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