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MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge: Respondent determined a deficiency in
petitioners' Federal income tax for 1987 in the amount of
$14,367, and an addition to tax for that year under section
6651(a)(1) in the amount of $3,204.
All section references are to sections of the Internal
Revenue Code in effect for 1987, and all Rule references are to
the Tax Court Rules of Practice and Procedure.
After concessions, the issues remaining for decision are (1)
whether petitioners are entitled to deduct certain alleged
business expenses incurred by George H. Cooper (petitioner) in
excess of $18,869, the amount allowed by respondent, and (2)
whether petitioners are liable for the late filing addition to
tax under section 6651(a)(1). (The limitation on the amount of
petitioners' claimed Schedule A miscellaneous itemized deductions
is a mechanical adjustment; the allowable amount of such
deductions will be calculated under Rule 155, using the amount of
petitioners' adjusted gross income determined as a result of this
proceeding. The amount of self-employment tax due on the income
that petitioner received from Con Tex, Inc., is also a mechanical
adjustment, the amount of which will also be calculated under
Rule 155.)
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Last modified: May 25, 2011