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Respondent determined the following deficiencies in
petitioners' Federal income taxes, additions to tax, and
penalties:
Addition to Tax Penalty
Year Deficiency Sec. 6651(a)(1) Sec. 6662(a)
1990 $4,383 $202 $ 877
1991 5,481 91 1,096
1992 1,964 58 393
After concessions by respondent,2 the issues for decision
are: (1) Whether petitioners are entitled to charitable
contribution deductions, under section 170(a) for each of the
years in question, for contributions to a local singing group;
(2) whether petitioners are entitled to educational expense
deductions, under section 162(a) for each of the years in
question; (3) whether petitioners are precluded, under section
280A for each of the years in question, from deduction of losses
incurred from rental properties; (4) in the event section 280A is
not applicable to petitioners' rental properties, whether
petitioners have substantiated certain expenses; (5) in the event
section 280A is not applicable to petitioners' rental properties,
2
At trial, respondent conceded the addition to tax under sec.
6651(a)(1) for 1991. Respondent, at trial, made several other
concessions, principally with respect to the substantiation of
various expenses that were disallowed in the notices of
deficiency. Those concessions are noted in the body of the
opinion. A Rule 155 computation will be necessary in these
cases.
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