- 18 - we find that petitioners did not prove that during the years at issue Mr. Hawthorne was holding those properties for the produc- tion of income. We further find that, except for the real estate taxes conceded by respondent, see supra note 6, they are not entitled for 1993 and 1994 to deduct as Schedule A deductions the expenses that they claimed in Schedules C of their returns for those years.8 To reflect the foregoing and the concessions of the parties, Decisions will be entered under Rule 155. 8 In so holding, we reject petitioners' contention that they should be allowed to deduct as Schedule A deductions the Schedule C expenses that respondent disallowed for 1993 and 1994 because in the notice for 1992 respondent allowed petitioners to deduct as Schedule A deductions the Schedule C expenses that respondent disallowed for that year. Respondent's determination for 1992 does not bind this Court for 1993 and 1994.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18
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