Aladar and Ilona G. Stolmar, Deceased - Page 2

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                                              Accuracy-Related Penalty                
               Year           Deficiency             Sec. 6662(a)1                    
               1994             $9,048                  $1,810                        
               1995             5,650                   1,130                         
               We must decide whether the determinations in the notices of            
          deficiency (notices) that have not been conceded by respondent              
          should be sustained.  We hold that they should.2                            
               Some of the facts have been stipulated and are so found.3              
               Petitioners Aladar Stolmar (Mr. Stolmar) and Ilona G.                  
          Stolmar, now deceased, resided in Canonsburg, Pennsylvania, at              
          the time the petitions in these cases were filed.                           
               Respondent determined in the notices, inter alia, that all             
          of the expenses which petitioners claimed in Schedules C of the             
          Federal income return (return) that they filed for each of the              
          years 1994 and 1995 "have been disallowed due to your failure to            

               1  All section references are to the Internal Revenue Code             
          in effect for the years at issue.  All Rule references are to the           
          Tax Court Rules of Practice and Procedure.                                  
               2  Respondent issued a notice of deficiency to Aladar                  
          Stolmar and Ilona G. Stolmar for each of the years 1994 and 1995.           
          They both filed a petition with respect to each of those notices.           
          There-after, Ilona G. Stolmar died, and the Court granted                   
          respondent's motion to dismiss these cases for lack of                      
          prosecution as to Ilona G. Stolmar, deceased. Pursuant to this              
          Opinion and the Court's Order dated Sept. 25, 1998, decisions               
          will be entered under Rule 155 as to each petitioner in the same            
          amounts for 1994 and 1995.                                                  
               3  Respondent objected to certain of the stipulations of               
          fact on grounds of relevancy, and petitioner Aladar Stolmar                 
          objected to certain other stipulations of fact on relevancy                 
          grounds.  We shall give the stipulations of fact whatever weight            
          we deem ap-propriate in deciding these cases.                               




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