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petitioner's 1991 Federal income tax in the amount of $6,062 and
an accuracy-related penalty under section 6662(a) in the amount
of $1,212.
After a concession by petitioner,2 the issues remaining for
decision are: (1) Whether petitioner is entitled to a business
bad debt deduction in the amount of $4,500 claimed on Schedule C;
(2) whether petitioner failed to report wage income in the amount
of $23.20; (3) whether petitioner is entitled to a claimed
casualty loss deduction in the amount of $6,490; (4) whether
petitioner is liable for the 10-percent additional tax imposed by
section 72(t), in regard to distributions he received from an
employer-provided pension plan and an individual retirement
account (IRA); and (5) whether petitioner is liable for the
accuracy-related penalty under section 6662(a).3
For the purpose of convenience, we have combined the
findings of fact and discussion of pertinent legal issues. Some
of the facts have been stipulated, and they are so found. The
2 Petitioner concedes that he made a mathematical error on
one of his Schedules C in the amount of $100. Due to the
resulting increase in petitioner's adjusted gross income, claims
for medical expense deductions were reduced by $7.50, claims for
casualty loss deductions were reduced by $10, and claims for
miscellaneous deductions were reduced by $2. Therefore, the
total adjustment attributable to petitioner's concession is
$119.50.
3 Respondent's notice of deficiency also reduced
petitioner's claimed medical expense and miscellaneous
deductions. We regard these adjustments as computational and do
not separately address them.
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