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petitioners are entitled to deduct in 1986 their basis in
the stock of Windsor Resources, Inc., on the ground that
the stock became worthless during the year; and (5) whether
the self-employment tax reported by Mr. Lemons should be
adjusted, as determined by respondent in the notice of
deficiency, and whether the self-employment tax reported by
Mrs. Lemons should be adjusted, even though no adjustment
was made in the notice of deficiency.
FINDINGS OF FACT
The parties have stipulated some of the facts.
The stipulation of facts filed by the parties and the
accompanying exhibits are incorporated herein by this
reference.
Petitioners are married individuals who filed
separate returns for each of the years in issue.
Respondent issued a separate notice of deficiency to
each petitioner and each filed a petition for
redetermination of the deficiency in this Court. At the
time they filed their petitions, both petitioners resided
in the State of Texas. The two cases were consolidated
pursuant to Rule 141. All Rule references are to the Tax
Court Rules of Practice and Procedure. Throughout this
opinion, all references to petitioner are to Mr. Woody F.
Lemons.
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