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$697.50, and an accuracy-related penalty under section 6662(d) in
the amount of $1,733.20.
After concessions, the issues for decision are as follows:
(1) Whether petitioners are entitled to deductions claimed for
unreimbursed employee business expenses; (2) whether petitioners
are entitled to deductions claimed for losses with respect to
certain real property held by them in 1992; (3) whether
petitioners are liable for an addition to tax under section
6651(a)(1); and (4) whether petitioners are liable for an
accuracy-related penalty under section 6662(d).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference.
At the time the petition was filed, petitioners resided in
League City, Texas.
During the taxable year 1992, petitioner Alonzo Bradley (Mr.
Bradley) was employed as an engineer by Paramax Systems Corp., an
affiliate of Unisys Corporation (Unisys). Unisys served as a
subcontractor for the Johnson Space Center (Space Center) Shuttle
Flight Operation of the National Aeronautics and Space
Administration (NASA). Mr. Bradley worked on the Shuttle
Operations Contract (SOC or SOP Contract) during 1992. As part
1(...continued)
Procedure.
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