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the following deficiencies in, addition to, and accuracy-related
penalties on petitioner's Federal income tax:
Addition to Tax Accuracy-Related Penalty
Year Deficiency Sec. 6651(a)(1) Sec. 6662(a)
11990 $2,437 --- $487
1991 2,951 $414 590
1 For 1990, the deficiency and penalty determined in the
notice of deficiency were $2,130 and $426, respectively. The
increased deficiency and penalty were claimed in respondent's
amended answer that asserts that petitioner is not entitled to a
dependency exemption for his daughter.
After concessions,2 the issues remaining for decision are:
(1) Whether petitioner is entitled to a dependency exemption for
his daughter in 1990 and his mother in 1991; (2) whether
petitioner is entitled to head-of-household filing status for
1991; (3) whether the claimed bad debt deduction in the amount of
$5,200 for 1990 should be treated as a business bad debt or a
nonbusiness bad debt; (4) whether petitioner is entitled to a
$9,100 theft loss deduction for 1991; (5) whether petitioner is
entitled to a $2,500 deduction for unreimbursed employee business
expenses incurred in 1991; (6) whether petitioner is liable for
2 With respect to 1990, petitioner has conceded that he is
not entitled to a deduction in the amount of $12,000 for amounts
withheld from his wages. For 1991, petitioner has conceded: (1)
He is not entitled to a deduction for medical expenses claimed on
Schedule A; (2) he may not claim his daughter, Jacqueline, as a
dependent; (3) with respect to a claimed deduction for property
taxes in the amount of $1,759, he is not entitled to a deduction
of $845 (respondent concedes that petitioner is entitled to a
deduction of $914); (4) with respect to a claimed deduction for
unreimbursed employee business expenses in the amount of $3,200,
he is not entitled to a deduction of $700; and (5) he is not
entitled to claim a deduction for a casualty loss in the amount
of $650.
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