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not explain the basis of the allocation between the 2 years.
Petitioner stipulated to those additional amounts of interest
income.
Of the other deductions of $94,105 No. 2 deducted for its
taxable year ended April 30, 1990, and $29,303 for its taxable
year ended April 30, 1991, the deficiency notice increased
petitioner's other deductions by $57,585 for a total of $124,854
for its taxable year ended July 31, 1989, and by $126,540 for a
total of $207,092 for its taxable year ended July 31, 1990.
These total increased other deductions of $184,125 exceed No. 2's
claimed total other deductions by an amount of $60,717. The
record does not explain the source of these additional
deductions, but neither party has challenged this adjustment.
Petitioner deducted depreciation of $16,851 for its taxable
year ended July 31, 1989, and $18,399 for its taxable year ended
July 31, 1990. No. 2 claimed no depreciation deductions.
Respondent disallowed $6,513 of petitioner's claimed depreciation
each year, the portion relating to a Chrysler New Yorker
automobile and a boat. Petitioner has conceded that adjustment.
Respondent determined an addition to tax for negligence
under section 6653(a) for the taxable year ended July 31, 1989,
and a penalty for negligence under section 6662(a) for the
taxable year ended July 31, 1990. Respondent determined the
addition and penalty on the full amounts of the deficiencies,
taking into account the tax shown on the tax returns filed by
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