Ramon and Irma Ortiz - Page 2

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          In the alternative to the fraud penalties, respondent asserts in            
          the answer to the petition that petitioners are liable for the              
          accuracy-related penalties for 1991 and 1992 pursuant to section            
          6662(a).                                                                    
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the years in issue, and             
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  
               After concessions,1 the issues to be decided are as follows:           
               (1)  Whether petitioner Ramon Ortiz had substantial amounts            
          of unreported self-employment income for 1991 and 1992 from his             
          wholesale used car business;                                                
               (2)  whether petitioners received additional interest income           
          for 1991 and 1992 in the respective amounts of $3,500 and $3,000;           
               (3)  whether petitioners are entitled to a capital loss in             
          1991 in the amount of $3,000;                                               
               (4)  whether petitioner Ramon Ortiz is liable for additional           
          self-employment taxes for 1991 and 1992;                                    
               (5) whether petitioner Irma Ortiz is liable for fraud                  
          penalties under section 6663 for 1991 and 1992; and                         

          1  Petitioners concede that they received interest of                       
          $18,000 in 1991 and $4,000 in 1992 which was not reported on                
          their Federal income tax returns.  Respondent concedes that                 
          $25,000 of petitioners' unreported income for 1992 is not subject           
          to self-employment tax.  These concessions, along with two                  
          computational adjustments for 1992 relating to a reduction in               
          itemized deductions and the recapture of a claimed earned income            
          credit, can be given effect in the Rule 155 computations.                   




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