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the October 7 notes in the respective principal amounts of $5,351
and $5,020 as nonbusiness bad debts for 1989. Pursuant to
respondent's concession, petitioner is entitled to a $3,000
capital loss deduction for each of the years at issue. Secs.
1221(b), 1212(b). Consequently, there is no substantial under-
statement of income tax for each of those years that is attribut-
able to the $3,000 capital loss deduction claimed by petitioner
for each such year.
With respect to the charitable contribution deduction that
petitioner claimed for each of the years at issue, petitioner
contends that he is entitled to those deductions and that there-
fore respondent erred in imposing the accuracy-related penalty
with respect to them. We disagree. We have sustained herein
respondent's determinations disallowing the charitable contribu-
tion deductions claimed by petitioner for the years at issue. On
the record before us, we sustain respondent's determinations
imposing the accuracy-related penalty for each such year to the
extent that it is attributable to those claimed deductions.
With respect to the $7,633 deduction for wages and salaries
claimed by petitioner in his 1991 Schedule E, that claimed
deduction resulted in a 1991 Schedule E "total loss" of $6,951
that petitioner used to reduce his income for 1991. Petitioner
concedes that he is not entitled to the $7,633 deduction for
wages and salaries and the $6,951 "total loss" that he claimed in
his 1991 Schedule E. However, he contends (1) that, in addition
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