Bradley G. Bjelk - Page 14

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          this record that respondent's determination that petitioner had             
          unreported income of $29,147 is erroneous.  We accordingly                  
          sustain respondent's determination of such unreported income only           
          to the extent of $15,748; this is in addition to the unreported             
          wages of $14,239, and the unreported interest income of $13, to             
          which the parties have stipulated.  In addition, since we have              
          found that petitioner paid home mortgage interest of $6,285,7               
          petitioner is entitled to a deduction in that amount, although              
          respondent's allowance of the standard deduction in the notice              
          must be adjusted accordingly.  Petitioner has not substantiated             
          any other Schedule A deductions.                                            
          1989                                                                        
               The parties have stipulated that petitioner received wages             
          of $1,944 in 1989.                                                          
               The parties have further stipulated that petitioner sold               
          real property located at the 11th Street address in 1989 for a              
          gross sales price of $69,500.8  In connection with the trial of             
          this case, petitioner completed and signed a 1989 Federal income            
          tax return on which he claimed certain expenses of sale of this             

               7 We make no provision for the $9,698 in mortgage interest             
          that the parties stipulated petitioner paid with respect to the             
          Crazy Horse property because petitioner admitted to a "net                  
          profit" estimate from the Crazy Horse Saloon, which would have              
          been net of mortgage interest expense.                                      
               8 Although the notice of deficiency for 1989 determined                
          income from real estate sales in the amount of $139,000,                    
          respondent now concedes that the gross sales price received by              
          petitioner was $69,500 rather than $139,000.                                




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