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Bear Auto Air, and Arctic Auto Air Electric. His objection to
each question was overruled, and he was ordered to answer. His
answer: "I will remain silent at this time on that question."
Accordingly, we hold that petitioner received and failed to
report employee wages, nonemployee compensation, and unemployment
compensation in the amounts determined by respondent for the
taxable years in issue.
The second issue for decision is petitioner's proper filing
status for the taxable years in issue.
In the statutory notices of deficiency, respondent
determined that petitioner's proper filing status for 1992, 1993,
and 1994 was single. However, respondent conceded at trial that
petitioner was married during the taxable years in issue. Since
petitioner did not make a single return jointly with his wife
under section 6013, we hold that his proper filing status for
1992, 1993, and 1994 was married filing separately. Sec. 1(d).
The third issue for decision is whether petitioner is
entitled to dependency exemption deductions for his two sons for
the taxable years in issue.
In the statutory notices of deficiency, respondent did not
allow petitioner dependency exemption deductions for his two sons
for 1992, 1993, and 1994. At trial, respondent's counsel stated
that petitioner had presented "two birth certificates for
dependents." He further stated respondent's position with
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