- 3 -
After concessions by the parties,2 the issues for decision
are: (1) Whether petitioner may claim Schedule A deductions for
taxes and interest in excess of the amounts allowed by respondent
for the taxable years in issue. We hold he may, to the extent
set out below. (2) Whether pursuant to section 162, petitioner
may claim unreimbursed business expense deductions in excess of
the amounts allowed by respondent for the taxable years in issue.
We hold he may, to the extent set out below. (3) Whether
pursuant to section 280A, petitioner is entitled to deduct home
office expenses for the taxable years in issue. We hold he is
not. (4) Whether for 1980, petitioner had unreported interest
income of $853. We hold he did not. (5) Whether for 1979,
petitioner is entitled to a theft loss not previously claimed on
his return. We hold he is not. (6) Whether pursuant to section
6651(a)(1) petitioner is liable for additions to tax for his
failure to timely file Federal income tax returns for the taxable
2 At trial and on brief, respondent concedes that petitioner
correctly reported his share of his then law firm's partnership
income of $96,340 for 1979 and $88,428 for 1980.
Respondent further concedes that petitioner correctly
claimed Keogh plan deductions of $4,766 for 1979 and $4,150 for
1980.
Respondent further concedes that petitioner provided
receipts to verify the amounts set out below were spent by
petitioner for 1979 and 1980.
Item 1979 Amount Verified 1980 Amount Verified
Taxes $4,188 -0-
Interest 1,010 -0-
Auto 3,162 $1,739
Sailboat 13,572 17,270
T&E 3,109 1,950
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