Kenneth and Sheila Smith - Page 2

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               Respondent determined a deficiency in petitioners' Federal             
          income tax for 1994 in the amount of $9,200.                                
               After a concession by respondent,2 the issue remaining for             
          decision is whether petitioners are entitled to business expense            
          deductions.                                                                 
               Some of the facts have been stipulated and are so found.               
          The stipulations of fact and attached exhibits are incorporated             
          herein by this reference.  Petitioners resided in Phoenix,                  
          Arizona, on the date the petition was filed in this case.  All              
          references to petitioner in the singular are to Kenneth Smith.              
               All of respondent's substantive adjustments in the statutory           
          notice of deficiency involve amounts claimed with respect to                
          petitioner's involvement with Tracstar Simulcasting, Inc.                   
          (Tracstar).3  Tracstar provided live satellite transmission of              
          dog and horse races to various off-track betting (OTB) locations.           
          It installed all of the equipment at the racetracks and the OTB             
          locations necessary for sending and receiving the satellite                 
          signals.  The racetracks were generally located in Arizona, but             




          2         In the event that the Court holds that petitioners are            
          not entitled to the claimed Schedule C deduction for interest               
          paid with respect to their motor homes, respondent concedes that            
          petitioners are entitled to an additional sec. 163(h)(3)                    
          qualified residence interest deduction for such interest.                   
          3         Respondent's adjustment to petitioners' liability for             
          alternative minimum tax is computational and will be resolved by            
          the Court's holding on the issue in this case.                              




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