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We must decide the following issues with respect to 1989:
1. Whether petitioner failed to report $66,851 of wages
paid to him by his wholly owned corporation.
2. Whether petitioner may deduct mortgage interest in an
amount greater than allowed by respondent in the notice of
deficiency.
3. Whether petitioner is liable for the addition to tax for
late filing determined by respondent under section 6651(a)(1).
4. Whether petitioner is liable for the accuracy-related
penalty determined by respondent under section 6662(a).
We hold for respondent on all issues. Section references
are to the Internal Revenue Code in effect for the year in issue.
Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulated facts and exhibits submitted therewith are
incorporated herein by this reference. Petitioner resided in
Los Angeles, California, when he petitioned the Court.
Petitioner did not file a 1989 Federal income tax return
until August 2, 1993. Petitioner's 1989 tax return (Form 1040,
U.S. Individual Income Tax Return), which was prepared by
Nugit & Licker, C.P.A.'s on July 7, 1993, reported that
petitioner received $54,250 of gross receipts from his sole
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