Ronald P. Barranti and Stephanya M. Barranti - Page 2

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               All section references are to the Internal Revenue Code in             
          effect for the taxable year in issue, and all Rule references are           
          to the Tax Court Rules of Practice and Procedure, unless                    
          otherwise indicated.  All dollar amounts are rounded to the                 
          nearest dollar, unless otherwise indicated.  References to                  
          petitioner are to Stephanya M. Barranti.                                    
               After concessions,1 the issues for decision are:  (1)                  
          Whether petitioners are entitled to deduct the $5,852 loss                  
          sustained in renting the property to petitioner's brother and the           
          loss realized on the sale of petitioner's residential property.             
          We hold they are not. (2) Whether petitioners are liable for an             
          accuracy-related penalty pursuant to section 6662(a).  We hold              
          they are.                                                                   
               Some of the facts have been stipulated and are so found.               
          The stipulated facts and the accompanying exhibits are                      
          incorporated herein by this reference.  At the time the petition            
          in this case was filed, petitioners resided in Alamo, California.           
                                  FINDINGS OF FACT                                    
               On February 21, 1991, petitioner acquired by gift a joint              
          tenancy in her grandmother's house located in San Mateo,                    

               1Before trial, respondent conceded that petitioners are                
          entitled to deduct depreciation expense of $19,936, and $44,369             
          of the $65,187 expenses reported on Schedule C that were                    
          disallowed in the notice of deficiency.                                     
               Petitioners conceded that they are not entitled to deduct              
          $20,818 of the expenses they claimed on Schedule C and that they            
          understated dividend income by $1,724 on their return for 1993.             




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