Albert L. Barcroft - Page 5

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          tary compliance".                                                           
               On the record before us, we find that petitioner has non-              
          employee compensation income in the amounts of $121,823 and                 
          $108,914 for 1992 and 1993, respectively.  Except for the capital           
          gain determination in the notice for 1993 that respondent has               
          conceded and any correlative effect of that concession on the               
          computation of the additions to tax under sections 6651(a) and              
          6654(a) for 1993, we further find on the instant record that                
          petitioner has not satisfied his burden of showing error in any             
          of the other determinations in the notice.                                  
               To reflect the foregoing and the concession of respondent,             

                                             Decision will be entered                 
                                        under Rule 155.                               
























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