Maria M. Masloff - Page 4

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                  During 1989, petitioner received gambling winnings totaling                           
            $7,025 and is entitled to a Schedule A gambling loss in the same                            
                  During 1992, petitioner received pension income from                                  
            Prudential Insurance Company in the amount of $1,851.                                       
                  In 1989, petitioner purchased vacant land on Harper Lake                              
            Road in San Bernardino County (Harper Lake Road property) for                               
            $48,000.  In 1992, petitioner sold that property for $160,000.                              
            At settlement of the sale of the Harper Lake Road property,                                 
            various amounts were credited and debited against that sales                                
            price, as reflected in the seller's closing statement with                                  
            respect to that sale.  Petitioner incurred deductible costs                                 
            associated with the sale of the Harper Lake Road property in the                            
            amount of $17,402.  Petitioner realized a gain for 1992 from the                            
            sale of that property in the amount of $94,598.                                             
                  Petitioner and respondent resolved by agreement many of the                           
            determinations in the notice, as set forth in the stipulation.                              
            We therefore turn to the issues that remain for our                                         
            consideration.  Presumably in an effort to show that respondent's                           
            determination under section 6651(a)(1) for 1992 is wrong,                                   
            petitioner contends that she filed a return for that year.                                  
            However, the record is devoid of any evidence to support that                               
            contention.  Petitioner also contends that she is entitled to                               
            (1) a loss for 1988 from an alleged investment, (2) an increase                             

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