Joao Montoro and Neuza Paula - Page 2

                                          2                                           
               After concessions,1 the issues for decision are:                       
               (1)  Whether petitioners' taxable income from International            
          Best Buys was $23,574 in 1990 and $147,426 in 1991, as                      
          petitioners contend; $131,508 in 1990 and $396,905 in 1991, as              
          respondent contends; or some other amount.  We hold that                    
          petitioners' income from International Best Buys was $64,910 in             
          1990 and $201,992 in 1991.                                                  
               (2)  Whether petitioners may carry back net operating losses           
          of $15,976 to 1987 and $15,491 to 1988.  We hold that they may              
          not.                                                                        
               (3)  Whether petitioners are liable for (a) additions to tax           
          for negligence under section 6653 for 1987 and 1988 and                     
          substantial understatement of income tax under section 6661 for             
          1987; and (b) the accuracy-related penalty under section 6662(a)            
          for 1990 and 1991.  We hold that they are.                                  


               1 Petitioners concede that they failed to report the                   
          following income:                                                           
                                                  1990        1991                    
          IBM tax payments for Mr. Paula          $44,069     $51,271                 
          IBM severance payment to Mr. Paula      --      36,808                      
          Wages paid to Mrs. Paula by A&P         1,609          --                   
          Interest                                2,542          943                  
               Respondent concedes that petitioners are entitled to a                 
          foreign tax credit of $7,510.83 for 1991 relating to the IBM                
          severance payment to Mr. Paula.  Respondent also concedes that              
          petitioners may deduct a $141 penalty they paid in 1990 as the              
          result of a premature withdrawal of funds from a certificate of             
          deposit.                                                                    
               The Court expects the parties to compute petitioners' self-            
          employment tax liability and personal exemption phase-out (if               
          applicable) under Rule 155.                                                 




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