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storage space is subject to the provisions of section 280A; and
(4) whether petitioners are liable for the accuracy-related
penalties under section 6662(a) for negligence or disregard of
rules or regulations for the 3 years at issue. The remaining
adjustments in the notices of deficiency for 1990 and 1992
relating to the taxable portion of petitioners' Social Security
income is computational and will be resolved by the Court's
holdings on the contested issues.
Some of the facts were stipulated, and those facts, with the
annexed exhibits, are so found and are incorporated herein by
reference. Petitioners, husband and wife, were legal residents
of Platteville, Wisconsin, at the time their petitions were
filed.
Petitioner is highly educated, possessing degrees in
aeronautical engineering and European and Islamic laws, a juris
doctorate, a master of laws in international law and economics, a
doctorate of juridical science in comparative law, and a
doctorate of philosophy in political science and economics.
Petitioner speaks five languages.
Since 1961, petitioner has been employed, in various
political science-related positions, by the University of
Wisconsin-Platteville (the University) at Platteville, Wisconsin.
During the years 1975 through 1983, petitioner was chairman of
the political science department at the University. In 1983,
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