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amendment also states that Mr. Tillman is liable for larger
additions to tax on account of the increased deficiencies.
The cases were consolidated for trial, briefing, and
opinion. Following concessions, we must decide:
1. Whether petitioners may deduct expenses on their 1989,
1990, and 1991 Schedules C, that were not allowed by respondent.
2. Whether petitioners may deduct interest and taxes on
their 1989, 1990, and 1991 Schedules A, Itemized Deductions, that
were not allowed by respondent.
3. Whether unemployment compensation received by
Mrs. Tillman in 1989 is includable in petitioners’ 1989 gross
income.
4. Whether Mr. Tillman’s 1990 and 1991 Schedules C failed
to report income from sales of $22,197 and $43,475, respectively.
5. Whether Mr. Tillman failed to report income for 1990,
stemming from his receipt of an insurance payment covering the
theft of his fully depreciated truck.
6. Whether petitioners are liable for additions to their
1989, 1990, and 1991 taxes under section 6651(a)(1).
7. Whether Mr. Tillman is liable for additions to his 1990
and 1991 taxes under section 6654.
8. Whether petitioners are liable for a penalty for 1989
under section 6662(a).
We hold for respondent on all issues. Unless otherwise
stated, section references are to the Internal Revenue Code in
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