Gerald L. and Joy M. Zeidler - Page 2

                                        - 2 -                                         

               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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