Nathanael Roman - Page 34

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          to the other deductions that he claimed in that schedule, he is             
          entitled to deduct $595 for contract labor expenses and $60 for             
          automobile and travel expenses and (2) that he has 1991 Schedule            
          E "total income" of $26.  On the record before us, we sustain               
          respondent's determination imposing the accuracy-related penalty            
          for 1991 to the extent that it is attributable to the $7,633                
          expense deduction, and resulting "total loss", that petitioner              
          claimed in his 1991 Schedule E.                                             
               To reflect the foregoing and the concessions of the parties,           


                                                  Decision will be entered            
                                             under Rule 155.                          


























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