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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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