Astrida Terauds - Page 3

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          expenses under section 212, relating to rental property, which              
          was not allowed by respondent; (4) whether petitioner, for the              
          year 1987, is entitled to apply, as partial payment of the tax              
          shown as due and owing on her return, the amount of $2,899.89               
          held by respondent for her account, which was received by                   
          respondent pursuant to a levy, and whether petitioner is entitled           
          to an additional credit for the proceeds of a separate levy that            
          is not shown on respondent's transcript of account; (5) whether             
          petitioner is entitled to credits or refunds for overpayments of            
          her 1986 and 1987 taxes; and (6) whether petitioner is liable for           
          the additions to tax under section 6651(a)(1) for 1986 and 1987.3           
               Some of the facts were stipulated.  Those facts, with the              
          annexed exhibits, are so found and are incorporated herein by               
          reference.  At the time the petition was filed, petitioner's                
          legal residence was Long Beach, New York.                                   
               During the years at issue, petitioner was a systems engineer           
          for the Sperry Rand Corp.  Her 1986 Federal income tax return was           
          filed on April 15, 1992, and her 1987 return was filed on March             
          4, 1992.                                                                    
               Because there are several issues involved in this case, we             
          have combined our findings of fact and opinion with respect to              

               For 1986, respondent disallowed itemized deductions of                 
          $3,011, consisting of mortgage interest and property taxes.                 
          These disallowed amounts were allowed as deductions for rental              
          expenses.  Petitioner does not challenge the characterization of            
          these items as rental expenses.                                             

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