Robert and Ella M. Tolbert - Page 2

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          Unless otherwise indicated, all section references are to the               
          Internal Revenue Code in effect for the years in issue, and all             
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  
               After concessions, the issues remaining for decision are:              
          (1) Whether petitioners overstated gross income on their 1989               
          Schedule C; (2) whether petitioners are entitled to a theft loss            
          deduction in 1989; (3) whether petitioners are entitled to                  
          deductions for charitable contributions in 1989, 1990, and 1991;            
          (4) whether for 1991 petitioners are entitled to additional                 
          deductions on Schedule C or to an additional deduction for                  
          mortgage interest; and (5) whether petitioners are liable for the           
          section 6651(a)(1) addition to tax for 1990 and 1991.                       
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.  At the           
          time of the filing of their petition, petitioners resided in                
          Hyattsville, Maryland.                                                      
               During the years in issue, Robert Tolbert (petitioner)                 
          operated a construction business known as Tolbert's Construction.           
          Petitioner reported the income and expenses from this business on           
          Schedule C.  Petitioner did not maintain any books or records for           
          Tolbert's Construction during 1989, 1990, or 1991.                          
               Tolbert's Construction had several different jobs during               
          1989, including the following:                                              




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