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for decision are: (1) Whether we have jurisdiction to resolve
the issue of whether petitioner Charles F. Patterson (hereinafter
sometimes referred to as petitioner) is entitled to a net
operating loss carryover (NOL) in the amount of $113,259 claimed
on his 1991 return, and purportedly attributable to the tax years
1988 through 1990; (2) whether, if we do have jurisdiction over
the issue, petitioner is entitled to the claimed NOL carryover;
(3) whether petitioners are entitled to claimed casualty and
theft loss deductions attributable to their horse- and dog-
breeding activities in the total amount of $4,150 for the tax
year 1991;5 (4) whether petitioners are entitled to claim
amortization deductions for startup expenses attributable to
their horse-breeding activity in the total amount of $4,074 for
each of the tax years 1991 and 1992; (5) whether petitioners are
entitled to claimed depreciation expenses attributable to their
horse-breeding activity in the total amount of $9,900 for the tax
4(...continued)
With respect to 1992, respondent has conceded the following
issues: (1) That petitioners' horse-breeding activity was an
activity engaged in for a profit; (2) that petitioners are
entitled to $33,525 of the Schedule C expenses claimed on their
return, including depreciation expenses in the amount of $5,622;
(3) that petitioners did not receive unreported income in the
amount of $17,530; and (4) that petitioners are not liable
for the accuracy-related penalty under sec. 6662(c). Petitioners
concede that they are not entitled to $155 of the depreciation
expenses claimed on their return. Petitioners, however, claim
additional depreciation expenses in the amount of $899.
5 This represents the combined amounts claimed on
petitioners' individually filed returns.
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