Shirley Dean Emmons and Charles W. Emmons - Page 2

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          $2,002, and an accuracy-related penalty under section 6662(a) in            
          the amount of $2,670.                                                       
               After concessions,2 the issues for decision are as follows:            
          (1) Whether petitioners must recognize long-term capital gains              
          from the foreclosure sale in 1991 of two parcels of real property           
          held by them; (2) whether petitioners are entitled to a deduction           
          for ordinary losses for their equity interests in the properties            
          sold by foreclosure in 1991; (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(a) for substantial understatement of tax.                      
               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             
          Chicago, Illinois.  In 1991, petitioners owned two rental income            
          properties that they had owned for more than 1 year.  These                 
          properties were located in Chicago, Illinois, at 5335 South                 
          Honore (Honore property) and 7332 Campbell (Campbell property).             
               In 1991, petitioners' adjusted basis for the Honore property           
          was $32,963, and they were personally liable for a mortgage on              

               2 Petitioners did not contest and are therefore deemed to              
          have conceded respondent's determination that they had additional           
          interest income in 1991.  Rule 34(b)(4).                                    

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