Sita G. and Mangalore Krishna - Page 2

                                                - 2 -                                                 
            and all Rule references are to the Tax Court Rules of Practice                            
            and Procedure.                                                                            
                  After concessions,1 the issues to be decided are as follows:                        
                  1.    Whether petitioners are entitled to deduct certain                            
            expenses related to petitioner's medical practice that were not                           
            claimed on petitioners' return;                                                           
                  2.    whether petitioners are liable for the self-employment                        
            tax pursuant to section 1401(b) in the amount of $1,240;                                  
                  3.    whether petitioners are entitled to a rental loss                             
            deduction in the amount of $23,576; and                                                   
                  4.    whether petitioners are entitled to itemized deductions                       
            in the amount of $1,372.                                                                  
                                         FINDINGS OF FACT                                             
                  Some of the facts have been stipulated for trial pursuant to                        
            Rule 91.  The parties' stipulations of fact are incorporated                              
            herein by reference and are found as facts in the instant case.                           


            1     In the notice of deficiency, respondent determined that                             
            petitioners had unreported income from certain sources in the                             
            amount of $60,552.  At the calendar call in the instant case,                             
            petitioner Mangalore G. Krishna stated, "We don't have any                                
            objections to the amounts in question as far as the income."                              
            Accordingly, we consider the unreported income amounts to have                            
            been conceded.                                                                            
                  Additionally, in the notice of deficiency, respondent                               
            determined that petitioners were liable for an addition to tax                            
            pursuant to sec. 6651(a)(1) for failure to file timely their 1991                         
            income tax return.  At trial, petitioner Sita G. Krishna conceded                         
            the sec. 6651(a)(1) addition to tax.                                                      
                  Respondent conceded that petitioners are entitled to a                              
            withholding tax credit in the amount of $2,496, which was not                             
            included in the notice of deficiency.                                                     




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